Revenue and Taxation Code § 50147
ARTICLE 2. Suit for Refund
A person’s failure to bring suit or action within the time specified in this article constitutes a waiver of all demands against the state on account of any alleged overpayments.
ARTICLE 2. Suit for Refund
A person’s failure to bring suit or action within the time specified in this article constitutes a waiver of all demands against the state on account of any alleged overpayments.