Cal. Rev. & Tax. Code § 50120.2

The fee payer against whom a jeopardy determination is made may file a petition for the redetermination thereof, pursuant to Article 3 (commencing with Section 50114), with the department within 10 days after the service upon the fee payer of notice of the determination, and they shall, within the 10-day period, deposit with the department that security which the department determines to be necessary to ensure compliance with this part. The security may be sold by the department at a 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 subdivision (d) of Section 50113. After that sale, the surplus, if any, above the amount due under this part shall be returned to the person who deposited the security.