To obtain a release or subordination of any lien imposed by the Gift Tax Law, the taxpayer must file an application for the same with the State Controller. The application should explain fully the circumstances that require the release or subordination, and should fully describe the particular items for which the release or subordination is desired. If the application is made prior to the filing of the gift tax return, an affidavit may be required showing the value of the property for which the release or subordination is requested, the basis for such valuation, the total amount of gifts made during the calendar year and prior calendar years, and, in case the property is to be sold or otherwise transferred, the name and address of the purchaser or transferee and the consideration, if any, paid or to be paid by him.

As a condition to the granting of a release or subordination the Controller may require the taxpayer to furnish a bond or other security satisfactory to the Controller for the payment of the tax, interest, and penalties due. If a bond is required it shall run in favor of the State of California in an amount not less than the amount of the tax, interest, and penalties, shall be conditioned for the payment of such amount, and shall be executed by such sureties as the Controller may approve.

Note: Reference: Section 16066, Revenue and Taxation Code.