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(1988 Supp.) to appeal from a ruling of the Colorado Board of Assessment Appeals regarding the <br />tax-exempt smtus of a certain corporation, even though the Administrator lacked standing to appeal <br />under Colo. Rev. Stat. § 24-4-106(4), the provision governing standing to seek judicial review under <br />the Colorado Administrative Procedure Act. In holding that the more specilic provision controlled <br />with respect to the tax year during which it applied, the Suprerne Couri held that: <br />Section 24-4-I06 is part ofthe State Administrative Procedure Act (APA), a general <br />statute outlining, among other things, the availabi li ty of judicial review of any agency <br />action. §§ 24-4-102(1), 24-4-102(3). 24-4-106. By contrast, section 39-2-117(6) is <br />a narrow provision which addresses onlythe availability nfjudicia] review of Board <br />decisions reviewing the Administratur's determination on an exemption application. <br />The interpretation of a special provision such as section 39-2-117(6) together with <br />the general APA provision is controlled by secticm 24-4-107, l0A C.R.S. (1988), <br />which provides that <br />[t]his article [4 of title 24, the APA] applies to every agency of the <br />state having statewide territorial jurisdiction except [certain agencies <br />not relevant here]. It applies to every other agency to which it is <br />made to apply by specific statuiory reference; but, where there is a <br />conflict between this article and a specific atstutory provision <br />relating to a specilic agency, such specific statutory provision <br />shall control as to such agency. <br />Id. at ] 322 (emphasis supplied by Otc Supreme Court). <br />The specific judicial review provision set forth at Colo. Rev. Star. § 34-33-128 controls all <br />inconsistent aspects of § 24-4-1 Uti for precisely the same reason. In its recent brief to this Court, <br />Basin inexplicably fails to acknowledge Muurer or the legal principle it announces. Instead, the <br />company wrongly claims that the decision in Cheney v. Mined Lund Keclumution Board, 826 P.2d <br />367, 368 (Colo. App. 1991), dictates that "staztdards for judicial review found in the Colorado <br />Administrative Procedure Act apply to judicial review of the actions of the Mined Land Reclamation <br />Board: ' C:heneY does no such thing. Cheney applies the reconsideration rule act forth at Colo. Rev. <br />-7- <br />