Revenue and Taxation Code § 5143
ARTICLE 2. Refund Actions by Taxpayers
If a claim for refund relates only to the validity of a portion of an assessment, an action may be brought under this article only as to that portion.
ARTICLE 2. Refund Actions by Taxpayers
If a claim for refund relates only to the validity of a portion of an assessment, an action may be brought under this article only as to that portion.