N.Y. Tax Law § 251
Where the application of the provisions of this article is involved, the act of a recording officer in recording or refusing to record an instrument, his determination, if any, and the application of this article thereto, shall be subject to review in the first instance by the commissioner of taxation and finance. Such review may be requested, within the time provided for by section two hundred fifty-seven-a or two hundred sixty-three of this article, as the case may be, by a party to the instrument or person interested therein or in the property affected thereby or such review may be initiated by the commissioner of taxation and finance. After such review, the commissioner of taxation and finance shall notify (i) the party or person who has so requested such review or, in the case of such review initiated by the commissioner of taxation and finance, the party to the instrument or person interested therein or in the property affected thereby, and (ii) the city of New York, or the county treasurer, as the case may be, to whom the tax imposed by this article may be payable, of his determination. Such determination shall be fixed and irrevocable unless within ninety days of the mailing of such notice, the party or person, who has so requested such review, or, in the case of such review initiated by the commissioner of taxation and finance, any party to the instrument or person interested therein or in the property affected thereby, or the city of New York, or the county treasurer, as the case may be, to whom the tax imposed by this article may be payable, petitions the division of tax appeals for a hearing unless the parties mentioned in clauses (i) and (ii) of this section waive their right to petition in such matter. The division of tax appeals shall give not less than three days written notice of the time and place of hearing, to be served either personally or by mail on all persons who filed such a petition, upon the commissioner of taxation and finance and upon the city of New York or upon the county treasurer, as the case may be, to whom such tax may be payable. The administrative law judge shall take such proofs as may be necessary to establish a complete record and thereupon issue his determination. After such hearing, the division of tax appeals shall give notice of the determination of the administrative law judge to such party or person who so filed such petition, to such city or such county treasurer and to the commissioner of taxation and finance. Such determination may be reviewed by the tax appeals tribunal, as provided in article forty of this chapter, at the instance of any party to such hearing, and by the city of New York or the county treasurer, as the case may be, to whom such tax may be payable. The decision of the tax appeals tribunal may be reviewed as provided in section two thousand sixteen of this chapter except that the city of New York or the county treasurer, as the case may be, to whom such tax may be payable, may also apply for judicial review. The provisions of this section shall be construed as amplifying and extending the rights of review expressly provided in other sections of this article, and shall in no manner be deemed a restriction thereof.
N.Y. Tax Law § 251