Section 19383 Of Article 3. Suit For Refund From California Revenue And Taxation Code >> Division 2. >> Part 10.2. >> Chapter 6. >> Article 3.

. The credit of an overpayment of any tax in satisfaction of any tax liability shall, for the purpose of any suit for refund of the tax liability so satisfied, be deemed to be a payment in respect of the tax liability at the time the credit is allowed.