N.Y. Tax Law § 278

§ 278. Effect of failure to pay tax. No transfer of certificates\ntaxable under this article made after June first, nineteen hundred and\nfive, on which a tax is imposed by this article, and which tax is not\npaid at the time of such transfer shall be made the basis of any action\nor legal proceedings, nor, except in a proceeding under articles ten-c\nand twenty-six of this chapter, shall proof thereof be offered or\nreceived in evidence in any court in this state.\n