Section 1420. Limitations of time

(a) The provisions of the civil practice
  law and rules or any other law relative to limitations of time  for  the
  enforcement  of  a  civil  remedy  shall  not apply to any proceeding or
  action taken by the state or the commissioner of taxation and finance to
  levy, appraise, assess, determine or enforce the collection of  any  tax
  or  penalty  provided  by  this article. No assessment of additional tax
  shall be made after the expiration of more than  three  years  from  the
  date  of the filing of a return; provided, however, that where no return
  has been filed as provided by law or in the case of a willfully false or
  fraudulent return, the tax may be assessed at any time.
    (b) Where, before the expiration of the period prescribed  herein  for
  the  assessment  of  additional tax, a taxpayer has consented in writing
  that such period be extended, the amount of such additional tax due  may
  be  determined  at  any  time within such extended period. The period so
  extended may be further extended by subsequent consents in writing  made
  before  the  expiration  of  the  extended  period.  If  a  taxpayer has
  consented in writing to the extension of the period for assessment,  the
  period  for  filing  an  application  for  a  refund pursuant to section
  fourteen hundred twelve shall not expire prior to six months  after  the
  expiration of the period within which an assessment may be made pursuant
  to the consent to extend the time for assessment of additional tax.