Upon becoming final a Controller's determination shall thereafter have the same force and effect as an order fixing tax made by a court in a proceeding in which such an order may be made. Pursuant to Revenue and Taxation Code Section 14672 such order has the force and effect of a judgment in a civil action.

The determination is conclusive only as to such property as may have been included in transfers disclosed to the Controller before the determination was made.

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