Section 70. Review of administrator's decision

--(a) General.--A decision of
  the administrator shall be subject to judicial review at the instance of
  any  taxpayer  affected  thereby  in  the manner provided by law for the
  review of a final decision or action of administrative agencies  of  the
  city.  An  application by a taxpayer for such review must be made within
  four months after notice  of  the  decision  is  sent  by  certified  or
  registered mail to the taxpayer.
    (b)  Judicial  review  exclusive  remedy of taxpayer.--The review of a
  decision of the administrator provided by  this  section  shall  be  the
  exclusive   remedy   available   to   any   taxpayer  for  the  judicial
  determination of the liability of the taxpayer for the taxes imposed  by
  this local law.
    (c)  Assessment  pending  review;  review  bond.--Irrespective  of any
  restrictions on the  assessment  and  collection  of  deficiencies,  the
  administration  may  assess  a  deficiency  after  the expiration of the
  period specified in subdivision (a), notwithstanding that an application
  for judicial review in respect of such deficiency has been duly made  by
  the taxpayer, unless the taxpayer, at or before the time his application
  for  review  is  made,  has  paid the deficiency, has deposited with the
  administrator the amount of  the  deficiency,  or  has  filed  with  the
  administrator a bond (which may be a jeopardy bond under subdivision (h)
  of  section seventy-four) in the amount of the portion of the deficiency
  (including  interest  and  other  amounts)  in  respect  of  which   the
  application  for  review  is  made  and  all costs and charges which may
  accrue against him in the prosecution of the proceeding, including costs
  of all appeals, and with surety approved by a  justice  of  the  supreme
  court  of  the  state  of  New York, conditioned upon the payment of the
  deficiency (including interest and other amounts) as finally  determined
  and  such  costs  and  charges.  If  as  a  result  of  a  waiver of the
  restrictions on the assessment and collection of a deficiency  any  part
  of  the  amount determined by the administrator is paid after the filing
  of the review bond, such bond shall, at the request of the taxpayer,  be
  proportionately reduced.
    (d)  Credit,  refund  or  abatement  after review.--If the amount of a
  deficiency determined by the administrator is disallowed in whole or  in
  part  by the court of review, the amount so disallowed shall be credited
  or refunded to the taxpayer, without the making of claim  therefor,  or,
  if payment has not been made, shall be abated.
    (e)  Date of finality of administrator's decision.-- A decision of the
  administrator shall become final  upon  the  expiration  of  the  period
  specified in subdivision (a) for making an application for review, if no
  such  application  has  been  duly  made  within  such  time, or if such
  application has been duly made, upon expiration  of  the  time  for  all
  further judicial review, or upon the rendering by the administrator of a
  decision  in  accordance  with  the  mandate  of  the  court  on review.
  Notwithstanding the foregoing, for the purpose of making an  application
  for  review,  the decision of the administrator shall be deemed final on
  the date the notice of decision is sent by certified or registered  mail
  to the taxpayer.