2023 New York Laws › TAX - Tax › Article 8 - Department of Taxation and Finance; Commissioner of Taxation and Finance › 174-B - Limitation on the Time to Collect Tax Liabilities.

§  174-b.  Limitation  on  the  time  to  collect  tax liabilities. 1.
  Notwithstanding any provision of law  to  the  contrary  and  except  as
  otherwise  provided  in  this  section,  a  tax  liability  shall not be
  enforceable and every tax liability shall be extinguished  after  twenty
  years  from the first date a warrant could be filed by the commissioner,
  without regard to whether the warrant is filed. The first date a warrant
  could be filed means the day after the last day specified for payment by
  the notice and demand issued for the tax liability  where  there  is  no
  right to a hearing with respect to such notice and demand. The first day
  a  warrant  could  be  filed  shall  be  determined  without  regard  to
  subsection (c) of section  six  hundred  ninety  or  subsection  (c)  of
  section  one  thousand  ninety  of this chapter, unless the commissioner
  assesses the liability under either such subsection (c). When there is a
  right to a hearing with respect  to  a  notice  and  demand  for  a  tax
  liability,  the  first  date a warrant could be filed means the day that
  opportunity for a hearing or review has been exhausted.
2. This section shall apply to any tax that  is  administered  by  the
  commissioner.  Any  reference  to  "tax" in this section shall be deemed
  also to refer to special assessments, fees, interest, additions to  tax,
  penalties   and   other   impositions   that  are  administered  by  the
  commissioner.
3. When, before the expiration of the time prescribed in this  section
  to enforce the collection of tax, both the commissioner and the taxpayer
  have  consented  in  writing  to its collection after such time, the tax
  liability shall not be extinguished and the tax may be collected at  any
  time  prior  to  the expiration of the period agreed upon. The period so
  agreed upon may be extended by any subsequent agreement in writing  made
  before the expiration of the period previously agreed upon.
4.  The  provisions of this section shall supplement or be in addition
  to the procedures relating to collection or administration provided with
  respect to any tax covered by this section. Where a  provision  of  this
  section  is  inconsistent  with  any such provision with respect to such
  tax, the provisions  of  this  section  shall  apply.  For  purposes  of
  subsection  (c)  of section six hundred ninety-two and subsection (c) of
  section one thousand ninety-two of this  chapter,  if  the  commissioner
  does  not  file  a  warrant  within  six  years  of assessment, the time
  limitations in this section shall not apply and  the  tax  liability  is
  extinguished.  Nothing in this section shall be construed to prevent the
  commissioner from  accepting  any  payment  for  a  tax  liability  made
  voluntarily  by  a taxpayer after the time to collect such liability has
  expired and the liability is extinguished. When a warrant is filed,  the
  commissioner  may  include  a  date on that warrant indicating when such
  warrant expires and tax liability is extinguished.
5. If a tax liability could  have  been  first  warranted  before  the
  effective  date of this section, such liability shall not be enforceable
  and shall be extinguished after twenty years from  the  first  date  the
  warrant could have been filed by the commissioner.