New York Consolidated Laws, Real Property Actions and Proceedings Law - RPA § 203. Judgment in action adversely affecting the title, interest or claim of the state based upon tax deed

1. That the state shall have a lien upon such real property or part thereof described in such tax deed, prior and superior to all other liens, (a) for the amount of the unpaid taxes not adjudged illegal in such action for which such real property was sold or liable to be sold in the first instance and for which such tax deed was issued, together with fees, charges and interest;  (b) for the amount of the unpaid taxes not adjudged illegal in such action for which such real property was subsequently sold or liable to be sold, together with fees, charges and interest;  (c) for the amount of all taxes, fees and charges admitted or paid by the state upon such real property to the date of the entry of such judgment, together with interest thereon from the date of such admission or payment.  In the determination of the amount of such lien, establishment of payments of taxes on said real property by the adjudged or admitted owner of the property during any of the same years in which payments were also made by the state shall reduce the lien of the state by the larger of the two tax payments for each of the years affected by duplicate payments, and in the event that wholly identical areas are not affected by the duplicate payments the court shall have power to apportion and adjust the amount of the lien as equity may require.

2. That the state may foreclose such lien as a mortgage on real property is foreclosed, provided such lien remains unpaid after the expiration of one year from the entry of such judgment.

The remedy provided by this section for recovery of tax payments shall be in addition to any other remedy now or hereafter available in law or in equity.