Xerox Corp. v. Department of Taxation & Finance

*946A party aggrieved by an administrative determination generally must " 'exhaust all possibilities of obtaining relief through administrative channels before appealing to the courts’ ” (Young Men’s Christian Assn. v Rochester Pure Waters Dist., 37 NY2d 371, 375). That rule applies to a taxpayer challenge to determinations of the State Tax Commission (Allstate Ins. Co. v Tax Commn., 67 NY2d 999, 1001; Slater v Gallman, 38 NY2d 1, rearg denied 39 NY2d 832; Hahn v State Tax Commn., 134 AD2d 904). Plaintiff has been unable to establish any exception to the exhaustion doctrine which would allow it…