Violation of Discharge?

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Client filed a 7 in 2012 and has received a discharge. Last week, State Board Board of Equalization assessed him personally on a corporate liability. The corporation ceased to exist in September 2008, a fact acknowledged by the Board. I read the applicable Revenue and Taxation Code Section [6829(f)] as barring assessment more than 3 years after the BOE has notice that the corporation has ceased to exist. BOE claims that the assessment is not in violation of the discharge. Any thoughts?

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