Section 278. Effect of failure to pay tax

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No transfer of certificates
  taxable under this article made after June first, nineteen  hundred  and
  five,  on  which  a tax is imposed by this article, and which tax is not
  paid at the time of such transfer shall be made the basis of any  action
  or  legal  proceedings, nor, except in a proceeding under articles ten-c
  and twenty-six of this  chapter,  shall  proof  thereof  be  offered  or
  received in evidence in any court in this state.

                    
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