People ex rel. Equitable Holding Corp. v. Graves

The amendment of section 218 of the Tax Law by chapter 183 of the Laws of 1940 relates to procedure. It extends the time limit of a remedy. Being remedial, it is retroactive in its effect and applies to cases falling within the terms of the amended statute which would otherwise have been barred by the lapse of time measured by the superseded statute. The statute allowing a year for an application for revision after audit was an act of grace *328by the sovereign. The amendment is an extension of the grace in point of time and it applies, I think, to all cases coming within its literal terms.

The…