Tax Law, § 1413
The remedies provided by sections 575.15 and 575.16 of this Part are the exclusive remedies available to any person for the review of tax liability imposed by Article 31 of the Tax Law. No determination or proposed determination of tax or determination on any application for refund may be enjoined or reviewed by any action for declaratory judgment, an action for money had and received, or by any action or proceeding other than a proceeding under article 78 of the Civil Practice Law and Rules.
N.Y. Comp. Codes R. & Regs. Tit. 20 § 575.17