Cal. Rev. & Tax. Code § 30243
The person against whom a jeopardy determination is made may petition for the redetermination thereof pursuant to Article 5 of this chapter. They shall, however, file the petition for redetermination with the department within 10 days after the service upon them of notice of the determination. The person shall at the time of filing the petition for redetermination deposit with the department such security as it may deem necessary to insure compliance with this part. The security may be sold by the department at public sale if it becomes necessary in order to recover any amount due under this part. Notice of the sale may be served upon the person who deposited the security in the same manner as prescribed for service of notice by Section 30206. Upon any such sale, the surplus, if any, above the amount due under this part shall be returned to the person who deposited the security.
Ca. Rev. and Tax. Code § 30243