N.Y. Tax Law § 506
2. The fees, taxes, penalties and interest accruing under this article shall constitute a lien upon all motor vehicles and vehicular units which are owned by such carrier or of which he has the lawful use or control. The lien shall attach at the time of operation of any such motor vehicle or vehicular unit within this state and shall remain effective until the fees, taxes, penalties and interest are paid, or the motor vehicle or vehicular unit is sold for the payment thereof. Such liens shall be paramount to all prior liens or encumbrances of any character and to the rights of any holder of the legal title in or to any such motor vehicle or vehicular unit, provided, however, that: a. No lien for any additional tax assessed pursuant to this article shall be enforceable against any motor vehicle or vehicular unit which prior to such assessment had been transferred in good faith to a bona fide transferee for value. b. The lien of such tax shall be subject to the lien of any indebtedness secured by a chattel mortgage or conditional sales agreement existing against such motor vehicle or vehicular unit previous to the time when such tax became a lien, if: