Section 207. 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, and  this  section  shall  be  construed  as
  having  been  in  effect as of the date of the original enactment of the
  corporation tax law, 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  corporation to a person or corporation with intent to
  avoid payment of any taxes, or where with like intent  the  transfer  is
  made  to  a  grantee  corporation, or any subsequent grantee corporation
  controlled by such grantor or which has any community of  interest  with
  it,  either  through stock ownership or otherwise.  Nothing herein shall
  affect any action or proceeding now  actually  pending  to  enforce  the
  collection of such tax or penalty from such real estate.