New York Court of Appeals
Irwin Slater v. Norman F. Gallman
November 20, 197538 N.Y.2d 1
Summary
The New York Court of Appeals held that a taxpayer cannot challenge a State Tax Commission assessment by a declaratory judgment action without first exhausting the statutory administrative review process. The court affirmed the Appellate Division's order, emphasizing that the exclusive remedy under Tax Law §§374‑375 requires prior administrative exhaustion.