New York SCT Code § 63

Presumption of validity of tax
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§ 63. Presumption of validity of tax. It shall be presumed that every\ntax levied and assessment made is valid and regular, and that all the\nsteps and proceedings required by law were taken and had, until the\ncontrary shall be made to appear. Any action or proceedings commenced by\nany person or persons to test the validity or regularity of any tax\nlevied or assessment made shall be commenced within two years from the\ndate of the receipt of the tax warrant by the town receiver of taxes.\nThe invalidity or irregularity of any tax or assessment shall not be\navailable as a defense to any action or proceeding commenced after the\nexpiration of two years from the delivery of such warrant as aforesaid,\nor for the enforcement of any right or title, by virtue of any sale\nthereunder, unless an action or proceeding to test the validity or\nregularity of such tax or assessment shall have been commenced within\nthe time hereinbefore limited for commencing the same, and shall be\nstill pending, or such tax or assessment shall have been adjudged to be\nirregular and invalid.\n

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