California, United States of America
The following excerpt is from State Bd. of Equalization v. Balboa Ins. Co., 155 Cal.Rptr. 205, 89 Cal.App.3d 499 (Cal. App. 1978):
People v. United States Fire Ins. Co., supra, 61 Cal.App.3d at pp. 234-235, 132 Cal.Rptr. 139, therefore answers appellant's contention that Revenue and Taxation Code sections 6757 and 6757.5 define the extension of the three-year statute of limitations as against the taxpayer only. However, it [89 Cal.App.3d 503] does not directly deal with the question of whether the filing of the certificate must name both the principal and the surety in order to extend the statute of limitations against both. 5
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