New York Consolidated Laws, Tax Law - TAX § 1413. Remedies exclusive

The remedies provided by sections fourteen hundred eleven and fourteen hundred twelve of this article shall be the exclusive remedies available to any person for the review of tax liability imposed by this article.  No determination or proposed determination of tax or determination on any application for refund shall be enjoined or reviewed by any action for declaratory judgment, an action for money had and received, or by any action or proceeding other than a proceeding under article seventy-eight of the civil practice law and rules.