The provisions of subdivision 3-a of section 170 and sections 689, 690 and 2008 of the Tax Law shall apply in the event a taxpayer wishes to protest any action taken by the commissioner or the department as a result of this Part which gives rise to a right to a hearing under the Tax Law.
N.Y. Comp. Codes R. & Regs. Tit. 20 § 2396.12