Tax Law, § 1456(c)

The credit for the special additional mortgage recording tax shall not reduce the tax below the fixed minimum amount as described in Subpart 18-6 of this Title. If the taxpayer has an excess credit for the special additional mortgage recording tax after reducing the tax due for the taxable year to the fixed minimum amount, such excess may be carried forward to the following year or years and may be deducted from the taxpayer's tax for such succeeding taxable year or years.