Rev. & Tax. Code, § 43351

The taxpayer against whom a jeopardy determination is made may file a petition for the redetermination thereof, pursuant to Article 4 (commencing with Section 43301), with the California Department of Tax and Fee Administration within 10 days after the service upon the taxpayer of notice of the determination, but they shall, within the 10-day period, deposit with the California Department of Tax and Fee Administration such security as it deems necessary to insure compliance with the provisions of this part. The security may be sold by the California Department of Tax and Fee Administration 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 43201 or 43201.01. 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.