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Section Topics
 Cover Letter
1.1What is involved
1.2How much is involved
1.3Who is involved
2Two tax credit claims filed for 2006 are explained below.
2.1.Altus Venture, Affinity Ventures, Quartz Mountain Aerospace, OK Industrial Venture
2.3.Oak Hills Capital
3Oklahoma Tax Commission negligence and cover-up
3.1New evidence uncovered since the original letter.
3.2Copies of Oklahoma Tax Commission emails obtained
4Colorado land scam and tax credit fraud connection
4.1The scam
4.2What Happened?
4.2.1Place liens on the property
4.2.2Deplete the funds to pay off loans bank account Kickbacks and wire transfer fraud
5Coming unwound
5.1Colorado partners seize Altus Groups financial records
6Other noteworthy points related to tax credits include

Updated report to appropriate authorities - evidence of tax credit and bank frauds. Dated 07/10/2010 (cont)

4. Colorado land scam and Oklahoma tax credit fraud connection

4.1 The scam

The Colorado land scam case was a "loan to own scheme," involving more than $25 million. Below is a summary of the case as documented and described in the Colorado victims' evidence and posted on This evidence was found on the server the Altus Venture's had been using to manage MAPI and MAPI financial records, discussed below.

4.2 What happened?

Paul Doughty, the president of First State Bank Altus Oklahoma, and Don Anderson approached two Colorado landowners, Ron Sills and Roger Johnson, to enter into a partnership. The landowners would contribute their property. The Altus Group touting its association with a federally back bank would provide financial record keeping and Working Capital. F. Don Anderson, the president, one of the bank subsidiaries, would serve as the managing partner.

Doughty and Anderson's scheme was to gain ownership of as much as possible of 4,000-acre s of prime resort area property in and around the Steamboat Springs Colorado resort area. This scheme would use a variety of illegal methods under the umbrella of the trust of a federally regulated and backed bank.

The partnership, Mountain Adventures Properties Investments (MAPI), started operating in the spring of 2006, then grew and sold something on the order of $12-million plus in property and raised roughly the same in Capital by mortgaging the other Colorado partners' property, without their full knowledge.

Note: During this entire period, despite continued requests and court order, as of this date, four years later, the Altus Group has never provided the first financial statements.

4.2.1 Place liens on the property

After the Colorado landowners contribute property to the partnership, rather than raising working Capital and without the knowledge of the Colorado landowner partners, Doughty and Anderson would arrange on-demand loans, using the Colorado landowners' property as collateral. Doughty, as bank president, would loan the partnership money, and Anderson, as managing partner, would sign the liens. The loans would be far less than the value of the property mortgaged.

4.2.2 Deplete the funds to pay off loans

The next step was to deplete the partnership funds to ensure the partnership could not meet mortgage payments and Doughty foreclose on the property. It was this process, to deplete partnership funds, where most illegal and fraudulent acts occurred.

To expedite fund depletion, the Altus Group employed numerous methods, in addition to extravagantly irresponsible spending of partnership funds, including personal luxuries, homes, and cars. The illegal activities included, but were not limited to: bank and wire transfer fraud; use of mirrored bank accounts (View 1, View 2); forgery and embezzlement; failure to perform fiduciary. Copies found in MAPI Case Documents. View Mirrored bank accounts, bank and wire transfer fraud, forgery, and embezzlement. View

The Altus Group set up mirrored accounts for the Colorado partners at First State Bank Altus. Without knowledge of the Colorado partners, the Altus Group issued checks from the MAPI account to all partners, including the Colorado partners. Instead of giving the checks to the Colorado partners, the checks would be deposited in the First State Bank Altus mirrored accounts. Where the Colorado partners were not aware, the funds were there, and the Altus Group had custody of the account and funds. Loan Kickbacks View

In another angle to the scheme, Anderson, Doughty and their friends bought several lots using bank loans to finance 80%, MAPI would carry a 10% second loan and, for the record, the buyers a 10% down payment. On or about closing, the Altus Group would use the MAPI partnership account to repay (kickback) the 10% down payment to certain lot buyers that included themselves and friends. Bank and wire transfer fraud

Vectra Bank Colorado was a party to bank and wire transfer fraud; and failure to perform fiduciary. The primary MAPI account was at the local branch of Vectra Bank where David Bruni was president, was a party to assisting the scheme in multiple ways: failure to fulfill fiduciary responsibility relating to funds disbursements; Mirror Account at First State Bank of Altus Based Upon Vectra MAPI Account Activity; illegal wire transfer.

David Bruni was later hired to take over as president of MAPI, with a lucrative bonus, further depleting the MAPI funds, again without the full knowledge of the Colorado partners. This was another of the acts leading to the Colorado partners calling for an outside audit.

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