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I Taxation Code. <br /> 2 Notwithstanding that the District Attorney may bring <br /> 3 the action on behalf of the People, such action may not be made <br /> 4 binding on a state agency not made a party to the action. To the <br /> 5 extent the Stipulated Judgment purports to be a final <br /> 6 ladjudication of defendant' s tax and related penalty liability, it <br /> 7 is not binding on the Board. Furthermore, the Board has the <br /> 8 authority to bring an action to set aside the Stipulated <br /> 9 Judgment. <br /> 10 In County of Sacramento v. C. P. R. R. Co. ( 1882 ) 61 <br /> ll Cal . 250, the court held that in an action to recover state and <br /> 12 County taxes brought by the District Attorney, the District <br /> 13 Attorney had no authority to accept as payment of the state tax <br /> 14 less than the full amount sued for. (Id. , at 255 . ) The court <br /> 15 held that the Attorney General had the authority to bring a <br /> 16 motion to set aside the settlement of the state tax liability. <br /> 17 (Id. , at 254 . ) <br /> 18 In People v. Hy-Lond Enterprises, Inc. ( 1979 ) 93 <br /> 19 Ca1 .App. 3d 734 , the District Attorney of Napa County brought an <br /> 20 action for an injunction, civil penalties , and other relief , <br /> 21 lagainst Hy-Lona, an operator of skilled nursing homes . The <br /> 22 District Attorney and Hy-Lond entered a Stipulation and Order for <br /> 23 Judgment. The stipulation purported to limit the right of the <br /> 24 Department of Health Services to engage in its regulatory duties . <br /> 25 The Attorney General and the Department of Health Services <br /> 26 brought an action to set aside and vacate the judgment on the <br /> 27 grounds that it precluded the Department of Health Services from <br /> 6 . <br />