§ 219. 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, 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.