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The problem with this unchecked discretion is that it creates opportunities for inconsistent application among wholesale dealer licensees, which Florida prohibits under section 120.52(8)(d) of the Administrative Procedure Act (APA)

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In 2009, the Bureau of Alcohol, Tobacco and Firearms devoted just 2 percent of its budget to investigating tax evasion on alcohol or tobacco, with the other 98 percent focused on firearms and explosives