American Employers Group, Inc. v. Employment Development Department

Opinion

EPSTEIN, P. J.

American Employers Group, Inc., appeals from the dismissal of its action following the denial of its petition for writ of mandate and the sustaining of a demurrer without leave to amend. We find no error and affirm.

FACTUAL AND PROCEDURAL SUMMARY

Unemployment Insurance Code sections 135.1 and 135.2 1 codify the tax concept of unity of enterprise. Under these provisions, the Employment Development Department (EDD) is authorized to consolidate multiple businesses united by factors of ownership or control into a single employing unit for purposes of determining the rate of…