DUNIWAY, Circuit Judge:
Jean A. Wood is the owner of Jean A. Wood Nurses' Registry and Employment Agency, Inc., a corporation. We refer to them both as "Wood." The California Employment Development Department audited the Registry's books and levied an assessment of $41,806.93 in unpaid unemployment taxes. Wood and her company exhausted the available administrative procedures for review of the assessment. The next step, under California law, was to pay the tax, seek...
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