Plaintiffs claimed that defendant improperly charged them use tax on its lease-end vehicle turn-in fee. This decision holds that the suit was properly dismissed because plaintiffs did not first submit their claims to respondent California Department of Tax and Fee Administration and obtain its definitive ruling on the taxability question. Plaintiffs’ claims were barred by their failure to exhaust administrative remedies and were not entitled to a judicially created remedy because there is no prior legal determination resolving the taxability issue.