Section 16862 Of Article 2. Suit For Refund From California Revenue And Taxation Code >> Division 2. >> Part 9.5. >> Chapter 5. >> Article 2.

. After a hearing in which the Controller shall represent the state, the court shall review the Controller's appraisement and determination of tax, and, as the case may require, shall by judgment modify or confirm the appraisement or determination in whole or in part.