Statured of limitation time to take legal action against a CPA doe tax negliegance

Neither.  In NY, the statute of limitations for accountant's malpractice is three years from when the malpractice occurred.  Thus, if your accountant screwed up on March 25, 2014 preparing your 2013 tax return, you would have until March 25, 2017 to sue him/her on that claim.  However, there are some things which can extend the statute of limitations, including continuous representation (the limitations period on a malpractice claim generally does not start to run until after your accountant has ceased to act as your accountant) and (under some circumstances) concealment of the claim by the accountant.