frame the issues that may be subsequently litigated in a state refund action. See § 6933 (“Within 90 days after the mailing of the notice of the [Bjoard’s action upon a [refund] claim ..., the claimant may bring an action against the [B]oard on the grounds set forth in the claim.”); American Alliance Ins. Co. v. State Bd. of Equalization, 184 Cal.Rptr. 674, 678, 134 Cal.App.3d 601, 609 (1982) (“The claim for refund thus frames and restricts the issues for litigation.”). Therefore, the state court can review taxpayers’ arguments and evidence regarding the allegedly unconstitutional and erroneous tax assessment if taxpayers first raised them in their claim for a refund. See e.g., Barclays Bank Int’l Ltd. v. Franchise Tax Bd., 14 Cal.Rptr.2d 537, 540, 10 Cal.App.4th 1742, 1749 (1992) (<HOLDING>); Jimmy Swaggart Ministries v. Board of
holding under section 7422a that the district court lacked jurisdiction over a taxpayers refund claim because the taxpayer failed to file a refund claim before the statute of limitations had run holding that the statute as applied violates the commerce clause holding that the taxpayers sufficiently stated their commerce clause and due process clause challenges in their claim for a refund holding the double jeopardy clause applicable to the states through the due process clause of the fourteenth amendment holding that the due process clause prohibits states from requiring defendants to prove their incompetency by clear and convincing evidence