Section 8149 Of Article 3. Suit For Refund From California Revenue And Taxation Code >> Division 2. >> Part 2. >> Chapter 7. >> Article 3.

. If the board or the Controller fails to mail notice of action on a claim within six months after the claim is filed, the claimant may, prior to the mailing of notice, consider the claim disallowed and bring an action against the Controller or the board on the grounds set forth in the claim for the recovery of the whole or any part of the amount claimed.