In Nast v. State Board of Equalization (1996) 46 Cal.App.4th 343, after the FTB issued notices of proposed assessments, the taxpayer unsuccessfully protested the assessments, filed an appeal with the Board and then paid the taxes in dispute. (Id. at p. 345.) The Board heard and denied his appeal, and Nast filed a writ petition requesting that the Board be ordered to set aside its ruling, grant his petition for rehearing, make certain findings, and order the FTB to pay him a refund with interest. (Ibid.) The Board demurred to the petition on the ground Nast's exclusive remedy was an action for refund under Revenue and Taxation Code section 19382, and the trial court sustained the demurrer without leave to amend. (Id. at pp. 345-346.) On appeal, Nast contended he was entitled to relief by writ of mandate because the FTB failed to offer evidence or offered only hearsay, and the Board made rulings without evidence supporting its determination. He contended he was entitled to a writ of mandate " 'directing the Board to support its decision with appropriate findings based upon evidence properly received.' " (Nast v. State Board of Equalization, supra, 46 Cal.App.4th at p. 346.) The court of appeal affirmed the judgment. (Nast v. State Board of Equalization, supra, at pp. 346-347.)