Any taxpayer who is dissatisfied with any tax deficiency determined by the Controller (see Revenue and Taxation Code Sections 15801, 15802 and 15803), may, if he has paid the tax, sue to recover the tax by filing an action against the State in the superior court having jurisdiction (see Revenue and Taxation Code Sections 16401 and 16402). The action must be filed 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 claim of refund is denied by the Controller (see Revenue and Taxation Code Section 16221.5), whichever is later.

Note: Reference: Section 16251, Revenue and Taxation Code.