Section 11-2509. Remedies exclusive

The  remedies  provided  by sections
  11-2506 and 11-2507 of this chapter  shall  be  the  exclusive  remedies
  available  to any person for the review of tax liability imposed by this
  chapter; and no  determination  or  proposed  determination  of  tax  or
  determination  on  any  application  for  refund  by the commissioner of
  finance, nor any decision by the tax appeals  tribunal  or  any  of  its
  administrative  law  judges,  shall be enjoined or reviewed by an action
  for declaratory judgment, and action for money had and  received  or  by
  any  action  or  proceeding other than, in the case of a decision by the
  tax appeals tribunal sitting en banc, a proceeding in the  nature  of  a
  certiorari  proceeding under article seventy-eight of the civil practice
  law and rules;  provided,  however,  that  a  taxpayer  may  proceed  by
  declaratory  judgment  if  he  or she institutes suit within thirty days
  after a deficiency assessment  is  made  and  pays  the  amount  of  the
  deficiency  assessment  to  the  commissioner  of  finance  prior to the
  institution of such suit and posts a  bond  for  costs  as  provided  in
  section 11-2506 of this chapter.