Section 690. Review of tax commission decision

--(a) General.--A decision of
  the  tax  appeals  tribunal  shall  be subject to judicial review in the
  manner provided for by section two thousand sixteen of this chapter.
    (b) Judicial review exclusive remedy of  taxpayer.--The  review  of  a
  decision  of  the  tax  commission 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 article.
    (c) Assessment  pending  review;  review  bond.--Irrespective  of  any
  restrictions  on  the assessment and collection of deficiencies, the tax
  commission may assess a deficiency after the expiration  of  the  period
  specified  in  subsection  (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 tax
  commission the amount of the deficiency,  or  has  filed  with  the  tax
  commission  a bond (which may be a jeopardy bond under subsection (h) of
  section six hundred ninety-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 tax commission 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 tax commission 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  division  of tax appeals determination or
  decision.-- A determination  of  an  administrative  law  judge  in  the
  division   of   tax  appeals  shall  become  final  in  accordance  with
  subdivision four of section two thousand ten of this chapter. A decision
  of the tax appeals tribunal shall become final upon  the  expiration  of
  the  period  specified  in  subsection (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  tax  appeals
  tribunal  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 tax appeals tribunal shall
  be deemed final on the date the notice of such  decision  is  served  as
  provided in section two thousand sixteen of this chapter.