Before the commissioner collects any tax by levy, the commissioner shall give prominent written notice to the person liable to pay the same that, in like manner as a judgment creditor, the department has certain rights to enforce the warrant by levying upon real and personal property of the taxpayer. Such statement shall be made in clear and concise language readily comprehensible to the average reader and shall be set off from any other text or notice.
N.Y. Tax Law § 3016