N.Y. Comp. Codes R. & Regs. tit. 20, § 7-4.1
Tax Law, § 1092(h)
An action may be brought at any time by the Attorney General in the name of the State of New York, at the instance of the Tax Commission, to recover the amount of any unpaid taxes, additions to tax, penalties and interest due which have been assessed under article 9-A or 27 within six years prior to the date the action is commenced.