Section 313. 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  petroleum  business  to a person with intent to avoid
  payment of any taxes, or where with like intent the transfer is made  to
  a  grantee,  or  any  subsequent  grantee  controlled  by such petroleum
  business or which has any community of interest with it, either  through
  stock ownership or otherwise.