REDDEN, Judge:
These are de novo proceedings brought pursuant to 7 U.S.C. § 2023. The suits are brought by the owners of two retail food stores, who challenge the action of the Food and Nutrition Service (FNS) in disqualifying them from participation in the federal food stamp program for stated periods of time, one year and six months, respectively. The store owners move for summary judgment on the grounds that the penalty periods of disqualification imposed...
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