Masi v. Nagle

Opinion

SIMS, J.

Plaintiffs Peter Masi and Sheila Masi, doing business as California Home Cleaning (taxpayers), appeal from summary judgment entered in favor of defendant Alice Gonzalez, Director of Employment Development Department (EDD), in the taxpayers’ action for a refund of taxes assessed and collected by EDD as employer contributions under the Unemployment Insurance Code. Summary judgment was granted on the ground that payment of the entire assessment, which covered several quarterly reporting periods, was a precondition to suit. On appeal, the taxpayers contend their payment of that…