OPINION
JACOBSON, Presiding Judge.
We are asked in this appeal to determine when an application for sale of state trust land ripens into a "sale proceeding" for the purpose of determining what avenue of review is available to a disappointed sale applicant.
The Commissioner (Commissioner) of the Arizona State Land Department (Department) denied the application of Rail N Ranch Corporation (Rail N Ranch) to purchase 160 acres of state school trust land...
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