Section 38612 Of Article 2. Suit For Refund From California Revenue And Taxation Code >> Division 2. >> Part 18.5. >> Chapter 7. >> Article 2.
38612
. No suit or proceeding shall be maintained in any court for
the recovery of any amount alleged to have been erroneously or
illegally determined or collected unless a claim for refund or credit
has been duly filed pursuant to Article 1 (commencing with Section
38601).