FLOYD R. GIBSON, Senior Circuit Judge.
Petitioner Salvatore Pupillo appeals from the decision of the United States Department of Agriculture ("USDA") to impose a sanction on him under the Perishable Agricultural Commodities Act of 1930, 7 U.S.C. §§ 499a-499s (1976 & Supp. V 1981) ("PACA" or "the Act"). The sanction, which bars Pupillo from working for a licensee under the Act for at least one year, was based on USDA's finding that Pupillo was "responsibly...
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