Revenue and Taxation Code section 6829.5
(a)
Any officer, manager, partner, beneficial owner, or member of a shell company, as that term is defined in Section 6248, shall, notwithstanding any provision in the Corporations Code, be personally liable for any unpaid taxes, and any interest and penalties on those taxes, due under this part on the purchase of a vehicle, vessel, or aircraft.(b)
Personal liability may be imposed pursuant to this section only if the department can establish that the shell company stored, used, or otherwise consumed the vehicle, vessel, or aircraft in this state within 12 months from the date of purchase and failed to pay the tax to the seller or to remit the tax to the department or the Department of Motor Vehicles.(c)
Except as provided in subdivision (d), the sum due for the liability under this section may be collected by determination and collection in the manner provided in Chapter 5 (commencing with Section 6451) and Chapter 6 (commencing with Section 6701).(d)
A notice of deficiency determination under this section shall be served within three years after the last day of the calendar month following the quarterly period in which the department obtains actual knowledge, through its audit or compliance activities, that the shell company stored, used, or consumed the vehicle, vessel, or aircraft in this state.
Source:
Section 6829.5, https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC§ionNum=6829.5. (updated Sep. 30, 2026; accessed Oct. 5, 2026).
