OPINION
HARTZ, Chief Judge.
{1} After purchasing a liquor license at a foreclosure sale, Bank of Commerce (the Bank) applied for approval from the director of the Alcohol and Gaming Division of the Regulation and Licensing Department for transfer of the license. Such approval requires clearance from the Taxation and Revenue Department (the Department). See NMSA 1978, § 7-1-82 (1995). The Department refused to grant clearance until the...
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