N.Y. TAX Law § 207

§ 207. Limitation of time. The provisions of the civil practice law\nand rules relative to the limitation of time of enforcing a civil remedy\nshall not apply to any proceeding or action taken to levy, appraise,\nassess, determine or enforce the collection of any tax or penalty\nprescribed by this article, and this section shall be construed as\nhaving been in effect as of the date of the original enactment of the\ncorporation tax law, provided, however, that as to real estate in the\nhands of persons who are owners thereof who would be purchasers in good\nfaith but for such tax or penalty and as to the lien on real estate of\nmortgages held by persons who would be holders thereof in good faith but\nfor such tax or penalty, all such taxes and penalties shall cease to be\na lien on such real estate as against such purchasers or holders after\nthe expiration of ten years from the date such taxes became due and\npayable. The limitations herein provided for shall not apply to any\ntransfer from a corporation to a person or corporation with intent to\navoid payment of any taxes, or where with like intent the transfer is\nmade to a grantee corporation, or any subsequent grantee corporation\ncontrolled by such grantor or which has any community of interest with\nit, either through stock ownership or otherwise. Nothing herein shall\naffect any action or proceeding now actually pending to enforce the\ncollection of such tax or penalty from such real estate.\n