Section 11-1312. Reserves

In  cases  where the taxpayer has applied for a
  refund and has instituted proceedings under article seventy-eight of the
  civil practice law and rules to review a determination  adverse  to  the
  taxpayer  on  his  or  her  application  for refund or has deposited the
  amount of tax assessed in  connection  with  proceedings  under  section
  11-1310  of  this  chapter,  the  comptroller  shall  set up appropriate
  reserves to meet any decision adverse to the city.