2005 California Revenue and Taxation Code Sections 16860-16862 Article 2. Suit for Refund

16860.  Within four years from the last date prescribed for filing
the return or within one year from the date the tax was paid, or
within 90 days after a determination under Section 16851 is issued,
whichever is later, any person who has paid the tax may bring an
action against the state in the superior court having jurisdiction to
have the tax refunded, in whole or in part.
16861.  Process in the action directed to the state shall be served
on the Controller.
16862.  After a hearing in which the Controller shall represent the
state, the court shall review the Controller's appraisement and
determination of tax, and, as the case may require, shall by judgment
modify or confirm the appraisement or determination in whole or in
part.