Section 2016. Judicial review

A decision of the tax appeals tribunal, which
  is  not  subject to any further administrative review, shall finally and
  irrevocably decide all the  issues  which  were  raised  in  proceedings
  before  the  division  of  tax appeals upon which such decision is based
  unless, within four months after notice of such decision  is  served  by
  the  tax appeals tribunal upon every party to the proceeding before such
  tribunal by certified mail  or  personal  service,  the  petitioner  who
  commenced  the  proceeding  petitions  for judicial review in the manner
  provided by article seventy-eight of the civil practice law  and  rules,
  except as otherwise provided in this section.  Such service by certified
  mail  shall  be  complete  upon  deposit  of  such notice, enclosed in a
  post-paid properly addressed wrapper,  in  a  post  office  or  official
  depository  under  the  exclusive  care and custody of the United States
  postal service. The petitioner shall designate the tax appeals  tribunal
  and  the  commissioner  of  taxation  and  finance as respondents in the
  proceeding for judicial review.  The  tax  appeals  tribunal  shall  not
  participate in proceedings for judicial review of its decisions and such
  proceedings  for  judicial  review  shall  be commenced in the appellate
  division of the supreme court, third department. In all  other  respects
  the  provisions  and  standards  of  article  seventy-eight of the civil
  practice law and rules shall apply.  The record to be reviewed  in  such
  proceedings  for  judicial review shall include the determination of the
  administrative law judge, the decision of the tax appeals tribunal,  the
  stenographic  transcript  of  the  hearing before the administrative law
  judge, the transcript of any oral proceedings  before  the  tax  appeals
  tribunal  and  any  exhibit  or  document submitted into evidence at any
  proceeding in the division of tax appeals upon which  such  decision  is
  based.