Cal. Rev. & Tax. Code § 46302
The feepayer against whom a jeopardy determination is made may file a petition for the redetermination thereof, pursuant to Article 5 (commencing with Section 46351), with the department within 10 days after the service upon the feepayer of notice of the determination, but they shall, within the 10-day period, deposit with the department such security as it determines to be necessary to ensure compliance with this part. The security may be sold by the department 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 46202. 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.
Ca. Rev. and Tax. Code § 46302