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Argued: December 9, 1999

Spankey’s Auto Sales, Inc. (Spankey’s) appeals from an order of the State Board of Vehicle Manufacturers, Dealers and Salespersons *fn1 (Board) affirming the order of a hearing examiner imposing a civil penalty of $1,000 for the operation of an unlicensed branch lot, to wit, displaying vehicles at a local mall. We reverse.

Spankey’s is a used car dealer with its main lot in Mechanicsburg, Pennsylvania. On July 23, 1998, Spankey’s was issued a citation by Dennis Ertter (Ertter), an agent of the Board, alleging that Spankey’s operated an unlicensed branch lot in violation of the Board of Vehicles Act (Act). *fn2

 
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