N.Y. PBL Law § 17-A

§ 17-a. Abandonment of claims under defective tax sales; recovery of\ntaxes paid thereon by state. Where the claim of title of the state to\nany land is based on a tax sale, which title in the opinion of the\nattorney-general would be declared void by the courts, the commissioner\nof general services, on the filing with him of such opinion and the\nevidence upon which such opinion was based, may, by order, abandon any\nclaim of title to such land, but, notwithstanding such abandonment, the\npeople of the state shall have a lien upon the real property affected by\nthe abandonment, prior and superior to all other liens, for the amount\nof all taxes, fees and charges admitted or paid by the people upon such\nreal property to the date of the abandonment of the state's claim of\ntitle, together with interest thereon from the dates of payment.\nProvided such lien remains unpaid after the expiration of one year from\nthe date of the abandonment, the people of the state may foreclose such\nlien as a mortgage on real property is foreclosed; but in any such\naction establishment of payments of taxes on said land or any part\nthereof by the adjudged or admitted owner of the property during any of\nthe same years in which payments were also made by the people of the\nstate shall reduce the lien of the people by the larger of the two tax\npayments for each of the years affected by duplicate payments, and in\nthe event that wholly identical areas are not affected by the duplicate\npayments the court shall have power to apportion and adjust the amount\nof the lien as equity may require. This remedy for recovery of tax\npayments shall be in addition to any other remedy now or hereafter\navailable in law or in equity, and shall be without prejudice to any\ndefense or offset available to an adverse claimant in law or in equity.\n