REVENUE AND TAXATION CODE
SECTION 19755
19755. (a) (1) Notwithstanding Section 19057, and except as
provided in paragraph (2), with respect to proposed deficiency
assessments related to an abusive tax avoidance transaction, a notice
of a proposed deficiency assessment may be mailed to the taxpayer
within eight years after the return was filed, or within the period
otherwise provided in Article 3 (commencing with Section 19031) of
Chapter 4 of this part, whichever expires later.
(2) For notices mailed on or after August 1, 2011, with respect to
proposed deficiency assessments related to an abusive tax avoidance
transaction, a notice of a proposed deficiency assessment may be
mailed to the taxpayer within 12 years after the return was filed, or
within the period otherwise provided in Article 3 (commencing with
Section 19031) of Chapter 4 of this part, whichever expires later.
(b) This section shall apply to any return filed under this part
on or after January 1, 2000. Paragraph (2) of subdivision (a) shall
apply to taxable years that have not been closed by a statute of
limitations, res judicata, or otherwise, as of August 1, 2011.
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