§ 1140. Remedies exclusive. The remedies provided by sections eleven
hundred thirty-eight and eleven hundred thirty-nine shall be exclusive
remedies available to any person for the review of tax liability imposed
by this article; and no determination or proposed determination of tax
or determination on any application for refund shall be enjoined or
reviewed by an action for declaratory judgment, an action for money had
and received, or by any action or proceeding other than a proceeding
under article seventy-eight of the civil practice law and rules.