Grandfathering

Another smoke screen providing an excuse to slip in another $330 million under deadline pressure.

Section 25

A."Any person or entity that has obtained a favorable determination letter from the Oklahoma Tax Commission, prior to March 15, 2006, regarding the ability to claim or otherwise utilize any of the tax credits."....

B. "Such qualified investment is made prior to November 1, 2006...."

Sources have informed me that attorneys were brought in from out of state in a rush mode to generate these letters during the Grandfather window early June thru November 1, 2006. During the period 20 some new determination letters were issued amount to $330 million in tax credits.

This simply stating funds yet to be invested must be invested prior to November 1, 2006. Something very clear and unmistakable. Leaving the obvious question of why anyone would need a new ruling?

Most request for determination letters appear to be asking for a new determination for funds to be invested at a latter date.

The letters were very vague in referring to any favorable determination letter, received prior to March 15, 2006. Simply referring to dates of "some" prior communications, never specify any unique identifying criteria, such as file numbers or any other specifies that could identify the actual letter or contents. Several of these new request for rulings referred to the same series of six separate dates. Suggesting they were all referring to only one ruling. Very likely and entirely different investment.

Some of the prior ruling would have expired as they has exceeded the 18 month period allowed for an investment.

Some letters from the Tax Commission were dated the following business date after request of the request for ruling, suggesting this was a rubber stamp. Further suggesting that the tax commission is simply a rubber stamp.