N.Y. Comp. Codes R. & Regs. tit. 20 § 480.1
Tax Law, §§ 503, 508
The tax is imposed upon the carrier with respect to every motor vehicle which he operates on the public highways of this State. This is so whether the carrier owns the vehicle or merely leases it or whether the carrier is the person named in the permit. A carrier who operates a motor vehicle is liable for the tax although the permit therefor was obtained by another. Thus, if a lessee operates a motor vehicle under a lease for a period of 30 days or less although the lessor may have obtained the permit and plate therefor, the lessee is liable for the tax with respect to the operation of such motor vehicle. However, the statute also imposes liability for the tax upon the owner where the carrier and the owner of the motor vehicle are not the same person. In such case the liability is a joint and several one on both the carrier and the owner and the tax may therefore be collected from either one.
Example:
A leases a motor vehicle from B on a six months' lease. A obtains a permit therefor and operates 1,000 miles upon New York roads. A and B are liable for the tax with respect to such mileage.
N.Y. Comp. Codes R. & Regs. Tit. 20 § 480.1