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July 13, 2010
To: US Securities and Exchange Commission
Subject: Evidence of suspected fraudulent tax claims and failure to properly disclose, in SEC filings both fraudulent activities and insider gains.
Re: BOK Financial Corp (Stock symbol BOKF) and Cimarron Business Capital
An examination of BOK(1) state income tax credit claims, found in Confidential Oklahoma Tax Commission emails, reveals evidence, I submit, clearly suggests the following occurred:
BOK Financial Corp failed to fully and properly disclose:
I submit this information warrants a complete and thorough investigation to determine the following:
If as the evidence clearly suggest, BOK misrepresented financial transactions to obtain unearned tax credits, for both BOK and the personal benefit of insiders, totaling as much as $92 million and potentially more than $400 million.
Did BOK fail to fully disclose activities related to BOK's role in claiming to qualify for Oklahoma state income tax credits. Activities that may have included:
Notes:
(1) As used, here BOK collectively refers to BOK Financial Corp, subsidiaries and affiliates; most notably, a banking subsidiary BOK Oklahoma; and BOK Oklahoma subsidiaries' Cottonwood Valley Ventures and CVV Partnership.
(2) As used, here Cimarron refers to Cimarron Business Capital Company.
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