N.Y. Comp. Codes R. & Regs. tit. 20 § 416.7
Tax Law, §§ 289, 289-b(1)(f), (3)
Unpaid tax, and unpaid penalties and interest under this Part may be recovered by the attorney general by a civil action in the name of the people of the State and all penalties and interest due from the same person may be sued for in one action. Failure to do any act required by or under the provisions of article 12-A of the Tax Law is deemed an act committed in part at the office of the Department of Taxation and Finance in Albany for all purposes under the Tax Law. The certificate of the Commissioner of Taxation and Finance to the effect that a tax has not been paid, that a return has not been filed, or that information has not been supplied, as required by article 12-A, or that a claim for refund has been filed, is prima facie evidence of such acts or omissions.
N.Y. Comp. Codes R. & Regs. Tit. 20 § 416.7