CA Rev & Tax Code Section 19090

(a)

Claims for the deficiency and such interest, additional amounts and additions to the tax may be presented, for adjudication in accordance with law, to the court before which the receivership proceeding (or case under Title 11 of the United States Code) is pending, despite the pendency of an appeal to the board.

(b)

In the case of a receivership proceeding, no appeal shall be filed with the board after the appointment of the receiver.