New York Tax Code § 1140

Remedies exclusive
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§ 1140. Remedies exclusive. The remedies provided by sections eleven\nhundred thirty-eight and eleven hundred thirty-nine shall be exclusive\nremedies available to any person for the review of tax liability imposed\nby this article; and no determination or proposed determination of tax\nor determination on any application for refund shall be enjoined or\nreviewed by an action for declaratory judgment, an action for money had\nand received, or by any action or proceeding other than a proceeding\nunder article seventy-eight of the civil practice law and rules.\n

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