N.Y. Comp. Codes R. & Regs. tit. 20 § 5000.2
A compromise agreement relates to the entire liability of the taxpayer or other person against whom the administrative action was taken by the Department of Taxation and Finance, including taxes, interest, additions to the tax and penalties, with respect to which the offer in compromise is filed, and all questions of such liability are conclusively settled thereby. Neither the taxpayer nor the Department of Taxation and Finance shall, upon acceptance of an offer in compromise, be permitted to reopen the case for any reason, except upon a showing of fraud, malfeasance or misrepresentation of a material fact. Acceptance of an offer in compromise will not be a ground for compromise regarding other years or periods.
N.Y. Comp. Codes R. & Regs. Tit. 20 § 5000.2