What is the statute of limitations for a claim under section 5141, subdivision (b) of the California Tax Act?

The language of the statute is only susceptible to one reasonable and common sense interpretation. Section 5141, subdivision (b) provides that a taxpayer "may . . . consider the claim rejected and bring an action under this article." (Italics added.) It follows that the limitations period could not commence any earlier than six months, because an action could not be filed before it is statutorily permitted. Likewise, the limitations period could not commence after six months, because no lawsuit could be filed before the claim accrues. (Code Civ. Proc., 312 [civil action may only be brought "after the cause of action shall have accrued"]; see, e.g., Romano v. Rockwell Internat., Inc. (1996) 14 Cal.4th 479, 488-490.) Thus, although not expressly stated, the statute of limitations can only be interpreted to commence six months after a claim under section 5141, subdivision (b) is filed.