N.Y. Comp. Codes R. & Regs. tit. 20, § 2396.12
The provisions of subdivision3-a of section 170 and sections 689, 690 and 2008 of the Tax Law shallapply in the event a taxpayer wishes to protest any action taken bythe commissioner or the department as a result of this Part whichgives rise to a right to a hearing under the Tax Law.