NY Tax L § 251 (2021)
2021 New York Laws TAX - Tax Article 11 - Tax on Mortgages 251 - Procedure for Review.

§ 251.  Procedure  for review. Where the application of the provisions   of this article is involved, the act of a recording officer in recording   or refusing to record an instrument, his determination, if any, and  the   application  of  this article thereto, shall be subject to review in the   first instance by the commissioner of taxation and finance. Such  review   may  be  requested,  within the time provided for by section two hundred   fifty-seven-a or two hundred sixty-three of this article,  as  the  case   may  be, by a party to the instrument or person interested therein or in   the property affected thereby or such review may  be  initiated  by  the   commissioner   of   taxation   and   finance.  After  such  review,  the   commissioner of taxation and finance  shall  notify  (i)  the  party  or   person  who  has so requested such review or, in the case of such review   initiated by the commissioner of taxation and finance, the party to  the   instrument  or  person  interested  therein  or in the property affected   thereby, and (ii) the city of New York, or the county treasurer, as  the   case  may be, to whom the tax imposed by this article may be payable, of   his determination. Such determination shall  be  fixed  and  irrevocable   unless  within  ninety  days of the mailing of such notice, the party or   person, who has so requested such review, or, in the case of such review   initiated by the commissioner of taxation and finance, any party to  the   instrument  or  person  interested  therein  or in the property affected   thereby, or the city of New York, or the county treasurer, as  the  case   may  be,  to  whom  the  tax  imposed  by  this  article may be payable,   petitions the division of tax appeals for a hearing unless  the  parties   mentioned  in  clauses (i) and (ii) of this section waive their right to   petition in such matter. The division of tax appeals shall give not less   than three days written notice of the time and place of hearing,  to  be   served  either  personally  or  by  mail on all persons who filed such a   petition, upon the commissioner of taxation and  finance  and  upon  the   city  of  New  York or upon the county treasurer, as the case may be, to   whom such tax may be payable. The administrative law  judge  shall  take   such  proofs  as  may  be  necessary  to establish a complete record and   thereupon issue his determination. After such hearing, the  division  of   tax appeals shall give notice of the determination of the administrative   law  judge  to  such party or person who so filed such petition, to such   city or such county treasurer and to the commissioner  of  taxation  and   finance. Such determination may be reviewed by the tax appeals tribunal,   as  provided  in  article  forty of this chapter, at the instance of any   party to such hearing, and by  the  city  of  New  York  or  the  county   treasurer,  as  the  case  may  be, to whom such tax may be payable. The   decision of the tax appeals tribunal may  be  reviewed  as  provided  in   section two thousand sixteen of this chapter except that the city of New   York  or  the county treasurer, as the case may be, to whom such tax may   be payable, may also apply for judicial review. The provisions  of  this   section  shall  be  construed  as amplifying and extending the rights of   review expressly provided in other sections of this article,  and  shall   in no manner be deemed a restriction thereof.