REPRESENTATION ISSUES; UNIT DETERMINATION/CRITERIA (SEE ALSO WHO IS AN EMPLOYEE?, SECTION 200) – Efficiency of Operation

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1309.00000 – REPRESENTATION ISSUES; UNIT DETERMINATION/CRITERIA (SEE ALSO WHO IS AN EMPLOYEE?, SECTION 200)
1309.04000 – Efficiency of Operation

Conclusory statements without specific detail are not sufficient to support the claim; p. 21, proposed dec.