FERREN, Associate Judge:
Abraham Kuflom, a taxi driver in the District of Columbia, appeals from a decision by the Bureau of Motor Vehicle Services (BMVS) to revoke his driver's permit because of twelve points on his driver's record. We reverse and remand.
I.
From January 31 to September 15, 1986, Kuflom received six tickets for moving violations. Initially, he did not respond to these tickets. When, however, BMVS suspended
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