New York Laws
Part 2 - Tax Fraud Acts and Penalties
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.

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