N.Y. Tax Law § 1413

§ 1413. Remedies exclusive. The remedies provided by sections fourteen\nhundred eleven and fourteen hundred twelve of this article shall be the\nexclusive remedies available to any person for the review of tax\nliability imposed by this article. No determination or proposed\ndetermination of tax or determination on any application for refund\nshall be enjoined or reviewed by any action for declaratory judgment, an\naction for money had and received, or by any action or proceeding other\nthan a proceeding under article seventy-eight of the civil practice law\nand rules.\n