Rev. & Tax. Code, § 43202

(a) Except in the case of fraud or intent to evade this part or authorized rules and regulations as set forth in subdivision (c) of Section 43201, willful or knowing provision of incorrect information or withholding of information as set forth in subdivision (c) of Section 43201.01, or failure to make a return, every notice of a determination of an additional amount due shall be served within three years after the date when the amount should have been paid or the return was due, or within three years after the return was filed, whichever period expires later. In the case of failure to make a return, the notice of determination shall be served within eight years after the date the report or return was due.

(b) The limitation specified in subdivision (a) shall not apply to a liability for the fees described in subdivision (c) of Section 25205.25 of the Health and Safety Code that is proposed to be determined with respect to a taxpayer if a notice of determination for the fee imposed pursuant to Section 25205.2 of the Health and Safety Code has been given pursuant to Section 43201 or 43350 for the same period and site, or with respect to a taxpayer that has paid the fee imposed by Section 25205.2 of the Health and Safety Code for the same period and site. The notice of determination with respect to the fees described in subdivision (c) of Section 25205.25 of the Health and Safety Code shall be given within 90 days from the date of final action of the California Department of Tax and Fee Administration or final judicial action, whichever is later, concerning liability for the fee imposed pursuant to Section 25205.2 of the Health and Safety Code.

(c) The limitation specified in subdivision (a) shall not apply to a liability for the fee imposed pursuant to Section 25205.2 of the Health and Safety Code that is proposed to be determined with respect to a taxpayer if a notice of determination for the fees described in subdivision (c) of Section 25205.25 of the Health and Safety Code has been given pursuant to Section 43201 or 43350 for the same period and site, or with respect to a taxpayer that has paid the fees described in subdivision (c) of Section 25205.25 of the Health and Safety Code for the same period and site. The notice of determination with respect to the fee imposed pursuant to Section 25205.2 of the Health and Safety Code shall be given within 90 days from the date of final action of the California Department of Tax and Fee Administration or final judicial action, whichever is later, concerning liability for the fees described in subdivision (c) of Section 25205.25 of the Health and Safety Code.