N.Y. Rac. Pari-Mut. Wag. & Breed. Law § 1410
The commission may perform audits of the books and records of an interactive fantasy sports operator with a permit or registrant, at such times and intervals as it deems appropriate, for the purpose of determining the sufficiency of tax payments. If a return required with regard to obligations imposed is not filed, or if a return when filed or is determined by the commission to be incorrect or insufficient with or without an audit, the amount of tax due shall be determined by the commission. Notice of such determination shall be given to the interactive fantasy sports operator liable for the payment of the tax. Such determination shall finally and irrevocably fix the tax unless the person against whom it is assessed, within thirty days after receiving notice of such determination, shall apply to the commission for a hearing in accordance with the regulations of the commission.
N.Y. Rac. Pari-Mut. Wag. and Breed. Law § 1410