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Regardless, the state legislature ratified and endorsed the new concept of administrative mandate in 1945 by enacting Code of Civil Procedure section 1094.5.
While the Constitution of California [10] and the Unemployment Insurance Code [11] prohibits state courts from impeding the collection of a tax, this does not apply to reserve account charges based on an employee's status so long as an assessment of unemployment insurance taxes has not been made. [12]