California Revenue & Taxation Code
Cal. Rev. & Tax. Code § 50124
# (a)
If the board determines that the amount of any fees, interest, and penalties are sufficiently secured by a lien on other property or that the release or subordination of the lien imposed under this article will not jeopardize the collection of the amount of the fees and penalties, the board may at any time release all, or any portion of, the property subject to the lien from the lien or may subordinate the lien to other liens and encumbrances.
# (b)
If the board finds the liability represented by the lien imposed under this article is legally unenforceable, the board may release the lien.
# (c)
A certificate by the board that any property has been released from a lien or that the lien has been subordinated to other liens and encumbrances is conclusive evidence that the property has been released or that the lien has been subordinated, as provided in the certificate.
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