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(29) This lawsuit was based on the argument that SSA performance
goals for the Associate Commissioner of Hearings and Appeals stated as a
reversal rate for ALJs would interfere with the ALJs' ability to
make independent de novo decisions, in accordance with the
Administrative Procedure Act. Because Circular 230 disciplinary
proceedings often involve complex tax transactions, the AICPA is
concerned about the use of ALJs who may lack tax expertise. In addition, the recommended
transmission and distribution rate increases for MetEd and PenElec
included in the ALJs recommendation are significantly less than the
amounts requested by the utilities. |
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