N.Y. Tax Law § 1807

§ 1807. Aggregation. For purposes of this article, the payments due\nand not paid under a single article of this chapter pursuant to a common\nscheme or plan or due and not paid, within one year, may be charged in a\nsingle count, and the amount of underpaid tax liability incurred, within\none year, may be aggregated in a single count.\n