N.Y. Second Class Cities Law § 164

§ 164. Right to review assessment or tax for local improvement\nlimited. No action or proceeding to set aside, vacate, cancel or annul\nany assessment or tax for a local improvement shall be maintained,\nexcept for total want of jurisdiction to levy and assess the same on the\npart of the officers, board or body authorized by law to make such levy\nor assessment or to order the improvement on account of which the levy\nor assessment was made. No action or proceeding shall be maintained to\nmodify or reduce any such assessment or tax except for fraud or\nsubstantial error by reason of which the amount of such tax or\nassessment is in excess of the amount which should have been lawfully\nlevied or assessed.\n