New York Consolidated Laws, Tax Law - TAX § 278. Effect of failure to pay tax

No transfer of certificates taxable under this article made after June first, nineteen hundred and five, on which a tax is imposed by this article, and which tax is not paid at the time of such transfer shall be made the basis of any action or legal proceedings, nor, except in a proceeding under articles ten-c and twenty-six of this chapter, shall proof thereof be offered or received in evidence in any court in this state.