In Decorative Carpets, Inc. v. State Board of Equalization (1962) 58 Cal.2d 252, a retailer sought a sales tax refund from the Board even though it conceded it had no intention of paying over the recovered refund to its customers. The Court of Appeal directed the trial court to enter judgment for the retailer "only if it submits proof satisfactory to the court that the refund will be returned to plaintiff's retailer's customers from whom the excess payments were erroneously collected." (Decorative Carpets, supra, 58 Cal.2d at p. 256.)