How has section 581a of the California Tax Code been interpreted in the context of the statute of limitations?

In construing and applying section 581a we must be mindful of its purpose in relation to the statute of limitations. The filing of an action stops the running of the period of limitations. The plaintiff has three years after that within which to serve process and file the return. This three year limitation 'was intended to prevent the indefinite extension of the life of the obligation in spite of the statute of limitations by simply commencing an action.' (Davis v. Hart (1899) 123 Cal. 384, 386, 55 P. 1060, 1061.)