California Revenue and Taxation Code § 2954

Revenue and Taxation Code
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(a) An assessee may challenge a seizure of property made pursuant to Section 2953 by petitioning for a writ of prohibition or writ of mandate in the superior court alleging: (1) That there are no grounds for the seizure; (2) That the declaration of the tax collector is untrue or inaccurate; and (3) That there are and will be sufficient funds to pay the taxes prior to the date such taxes become delinquent. (b) As a condition of maintaining the special proceedings for a writ, the assessee shall file with the tax collector a bond sufficient to pay the taxes and all fees and charges actually incurred by the tax collector as a result of the seizure, and shall furnish proof of the bond with the court. Upon the filing of the bond, the tax collector shall release the property to the assessee.

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