Section 13520 Of Chapter 4. Deficiency Determination From California Revenue And Taxation Code >> Division 2. >> Part 8. >> Chapter 4.

. In any case in which it is claimed that a deficiency has been determined in an erroneous amount, any person who is liable for the tax may, within three years after the determination was made, bring an action against the state in the superior court having jurisdiction to have the tax modified in whole or in part.