§ 1420. Limitations of time. (a) The provisions of the civil practice
law and rules or any other law relative to limitations of time for the
enforcement of a civil remedy shall not apply to any proceeding or
action taken by the state or the commissioner of taxation and finance to
levy, appraise, assess, determine or enforce the collection of any tax
or penalty provided by this article. No assessment of additional tax
shall be made after the expiration of more than three years from the
date of the filing of a return; provided, however, that where no return
has been filed as provided by law or in the case of a willfully false or
fraudulent return, the tax may be assessed at any time.

(b) Where, before the expiration of the period prescribed herein for
the assessment of additional tax, a taxpayer has consented in writing
that such period be extended, the amount of such additional tax due may
be determined at any time within such extended period. The period so
extended may be further extended by subsequent consents in writing made
before the expiration of the extended period. If a taxpayer has
consented in writing to the extension of the period for assessment, the
period for filing an application for a refund pursuant to section
fourteen hundred twelve shall not expire prior to six months after the
expiration of the period within which an assessment may be made pursuant
to the consent to extend the time for assessment of additional tax.