In any case in which a deficiency has been determined in an erroneous amount, the Controller may, within three years after the erroneous determination was made, set aside the determination or issue an amended determination in the correct amount.

Even though an amended determination is issued, or subsequent amended determinations are issued, any unpaid tax becomes delinquent after the last date prescribed by law for filing the return reporting the gift for which the determination is issued. (See Section 15905 and Revenue and Taxation Code Section 15905). See Section 15681 regarding penalties for failure to file or for late filing.

Note: Reference: Section 15803, Revenue and Taxation Code.