New York Tax Law Section 1807 - Aggregation.

  1807.  Aggregation.  For purposes of this article, the payments due
  and not paid under a single article of this chapter pursuant to a common
  scheme or plan or due and not paid, within one year, may be charged in a
  single count, and the amount of underpaid tax liability incurred, within
  one year, may be aggregated in a single count.

Last modified: February 3, 2019