Cal. Revenue and Taxation Code - RTC § 19411. Section 19411.
(a)
The Franchise Tax Board may recover any refund or credit or any portion thereof that is erroneously made or allowed to the taxpayer or any third party, including where the taxpayer or a related party caused, in any way, that erroneous refund, together with interest at the adjusted annual rate established pursuant to Section 19521, in an action brought in a court of competent jurisdiction in the County of Sacramento in the name of the people of the State of California within whichever of the following periods expires the later:
(1)
Two years after the refund or credit was made.
(2)
During the period within which the Franchise Tax Board may mail a notice of proposed deficiency assessment.
(b)
Abatement of interest under this section is governed by subdivision (c) of Section 19104.