June 7, 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 Oklahoma Tax Commission emails, reveals evidence, I submit, clearly suggests the following occurred:
- BOK Financial Corp and subsidiaries including the Bank of Oklahoma;
- in collusion with Cimarron Business Capital, and state agencies;
- fraudulently obtained $91 million in unearned state income tax credits;
BOK Financial Corp failed to fully and properly disclose:
- certain activities related to obtaining unearned Oklahoma state income taxes;
- how these unearned tax credits were disbursed,
- insiders received $72 million in unearned and undisclosed profits from these activities.
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:
- misrepresenting what appears to be interest bearing loans as investments to obtain unearned tax credits;
- full value of tax credits received;
- values of tax credits sold to insiders for as little as 20 cents on the $1;
- value of benefits to insiders in the form of state income tax evasion.
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