Cal. Rev. & Tax. Code § 55102

The feepayer against whom a jeopardy determination is made may file a petition for redetermination thereof, pursuant to Article 3 (commencing with Section 55081), 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 any security that it deems necessary to ensure compliance with the provisions of this part. The security may be sold by the department at public sale if it becomes necessary to do so 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 55061. 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.