In Lennane v. Franchise Tax Bd. (1994) 9 Cal.4th 263, the Supreme Court granted review in order "to construe tax statutes Revenue and Taxation Code sections 17063.11 and 18162.5 that have been repealed yet continue to govern the disposition of outstanding tax claims in excess of $ 300 million." The Court reviewed the propriety of a 1991 assessment under the 1986 laws, ruling that the code sections repealed in 1989 "continue to apply to income tax returns for the year 1986." (Id. at pp. 266, fn. 2, 267.)