The Controller's determination of tax becomes final 60 days after the date on which notice thereof is mailed as specified in Section 14562 and Revenue and Taxation Code Section 14562 unless within such time a proceeding in which the tax may be fixed by court order is instituted. Written notice of such a proceeding must be given to the Controller. If such a proceeding is timely instituted, the Controller's determination is superseded and determination of the tax will proceed as if no Controller's determination had been made.

Note: Reference: Section 14563, Revenue and Taxation Code.