§ 207. Limitation of time. The provisions of the civil practice law
and rules relative to the limitation of time of enforcing a civil remedy
shall not apply to any proceeding or action taken to levy, appraise,
assess, determine or enforce the collection of any tax or penalty
prescribed by this article, and this section shall be construed as
having been in effect as of the date of the original enactment of the
corporation tax law, provided, however, that as to real estate in the
hands of persons who are owners thereof who would be purchasers in good
faith but for such tax or penalty and as to the lien on real estate of
mortgages held by persons who would be holders thereof in good faith but
for such tax or penalty, all such taxes and penalties shall cease to be
a lien on such real estate as against such purchasers or holders after
the expiration of ten years from the date such taxes became due and
payable. The limitations herein provided for shall not apply to any
transfer from a corporation to a person or corporation with intent to
avoid payment of any taxes, or where with like intent the transfer is
made to a grantee corporation, or any subsequent grantee corporation
controlled by such grantor or which has any community of interest with
it, either through stock ownership or otherwise. Nothing herein shall
affect any action or proceeding now actually pending to enforce the
collection of such tax or penalty from such real estate.