Sec. 485.2. Judicial review

Tax Law, § 510

At any time within 30 days after service of notice of the decision of the State Tax Commission and upon depositing or securing the amount of tax and penalty due with the commission, and securing the costs and charges of the proceeding, the taxpayer may institute a proceeding in the Supreme Court of the State of New York under article 78 of the Civil Practice Law and Rules to review such determination. This remedy is the exclusive remedy available to any taxpayer to secure a judicial determination of his liability for taxes under article 21 of the Tax Law.