Date: July 2, 2010
To: Cognizant agencies

Subject: Federal tax evasion based on state income tax credit fraud

Multiple cases of tax credit fraud involving two similar programs. Differences, in programs, are subtle, and serve no useful benefit; other than facilitate abuses: separate different users; who if anyone certifies; and categorizes which tax credits will be issued as tax refunds through another off the books program.

Considering the number of cases, entities, individuals involved, magnitude, and complexity, it would best serve the interest of all, initially limit the scope to four cases where the complete evidence has been uncovered, and demonstrate most aspects of the fraud. Information on the remaining cases is available at your request.

1. Tax evasion and tax credit fraud on unearned gains thru Oklahoma's "Venture Capital" tax credit program. Involves Oklahoma Tax Commission; a state trust, the Oklahoma Capital Investment Board (OCIB); Cimarron Business Capital; and BOK Financial Corp (BOKF : NASDAQ).

2. Update to Ltr to Internal Revenue Service dated June 30, 2009, Subject: "Reporting Fraud."

Tax evasion and tax credit fraud on unearned gains thru Oklahoma's "Capital Formation Incentive Act" tax credit programs. Oklahoma Tax Commission: and

A. First State Bank Altus OK, Altus Venture: affiliates, operatives, and beneficiaries.

• Affinity Ventures;
• Quartz Mountain Aerospace;
• Paul Doughty;
• F. Don Anderson;
• Chaparral Energy;
• others.

B. Scissortail: affiliates, operatives, and beneficiaries.

• Oklahoma Global Motors;
• Westheimer Aviation;
• Commuter Air;
• Ardmore Biodiesel;
• Double B Energy Services;
• Sidney Clarke;
• Marc Nuttle;
• Josh Brim.

C. Oak Hills Capital: affiliates, operatives, and beneficiaries.

• Avondale Investments.
• Donald Dillingham.

3. Colorado land scam, affiliates, parties, and beneficiaries:

• Oklahoma Banking Department;
• First State Bank Altus OK;
• Altus Venture and affiliates;
• Paul Doughty;
• F. Don Anderson;
• Bill Grissom.

It should come as no surprise the same names keep popping up.

My role: discoveries, past successes, and testimonials

More than three years ago, the website Prowlingowl.com was launched to expose Oklahoma's tax credit fraud. As a result, private citizens and state employees/officials have helped obtain information ranging from copies of tax commission reports, letter rulings, and internal emails. Victims of a Colorado land scam involving the Altus Group (First State Bank Altus Oklahoma and affiliates) provided the information they found on an Altus Group computer, demonstrating bank fraud, among other crimes. The computer files also contain information pertaining to the Altus Groups' involvement in Oklahoma tax credit fraud.

This investigation, aided by the above information, helped expose bank fraud occurring at First State Bank Altus Oklahoma that led to FDIC and Federal Reserve Board Cease and Desist orders, an audit, and seizure of the bank. A still ongoing investigation ensued. Under the new ownership of the bank, the discovery of $643 million in fraudulent loan documents, the president, Paul Doughty, issued to six investment banking funds he managed.

Evidence has been uncovered, revealing in one case, Paul Doughty used $189 million of the fraudulent loans to inflate $32 million actually invested in Quartz Mountain Aerospace to claim a total $221 million was invested during 2006. As a result, Doughty collected $66 million in tax credits. Doughty had promised investors a guaranteed $2 in tax credits for each $1 invested. When word got out to the media and legislators, Doughty claimed the $189 million was to be used to purchase airplanes built by QMA to lease to flight training schools. That was an obvious impossibility for reasons too detailed to present here, but can be found at prowlingowl.com. None the less, Doughty was allowed to continue.

Quartz Mountain Aerospacr went broke and closed its doors in 2008, later filing for bankruptcy. Only five flyable planes were ever built, the sum total flying time for all five flyable planes was 26 hours and 11 minutes. One plane took 16 flights and flew 20 hours and 3 minutes of that time. The other four logged a total of 6 hours and 8 minutes.

In a recent open letter to the Altus Times, John Daniel, the president of Quartz Mountain Aerospace at the time, attested to the fact Quartz Mountain Aerospace has only received the $32 million and none of the $189 million. Again state officials turned their backs, as will be explained.

And, other similar cases, mentioned above and other parties are involved. Equally, if not more important, are the direct involvement of the Oklahoma Tax Commission; and the willingness of all other state officials to continue turning their backs' as has been done for years.

Respectfully,

Prowling Owl

Continued >>

Enclosures:
1) Updated version of the letter, reporting tax credit fraud and a land scam. View
2) BOK Financial Corp, Federal tax evasion, tax credit fraud, and bank fraud. View