Hansen, Barnett & Maxwell (HB&M)
This opinion letter was written in August of 2005. It was initially discovered on the "SolarEagles.com" website (now defunct) back in March of 2006. "SolarEagles LLC" claimed to be an "Independent Representative of International Automated Systems, Inc."
The letterhead resembled the official HB&M letterhead, except it had several variations from a real HB&M letterhead. HB&M acknowledged writing the text of the letter, but they didn't approve its publication.
The "properties" of the PDF file identify "Chris Taylor" as the last editor of the file. At the time, Chris Taylor was an IAS employee and Director. He left the company in March of 2012.
The opinion letter from IAS / "SolarEagles.com" is here:
HB&M Letter From IAS/SolarEagles
A list of the differences can be found here:
HB&M LetterHead Differences
The Header of an actual HB&M letter is here:
HB&M Header From HB&M
The Footer of an actual HB&M letter is here:
HB&M Footer From HB&M
Anderson Law Center, P.C.
This opinion letter was provided to RaPower3 "team members" on Nov 22, 2010.
The letter first appeared on RaPower3.com on December 2, 2010. At that time, it was dated Dec 1, 2010. That's more than a week after it was sent to "team members".
The letter was "signed" by a non-existent company: "Law Center, P.C.". It was displayed as text on a RaPower3 web page.
Law Center, P.C. letter - Dec 2, 2010
The letter was removed from the RaPower3 site in August of 2011, nine months after it was first "published". All the rest of the tax credit program information was also removed at that time.
In November of 2013 (27 months later), the letter re-appeared on a revamped RaPower3.com website.
That was 36 months after it originally appeared. This time it was on a corporate letterhead and was signed with the full name of the authors: "Anderson Law Center, P.C.". It was dated August 8, 2012. That is also the date of the letter currently on RaPower3.com.
Anderson Law Center, P.C. letter - November 2013
Note: the date on the November 2013 letter had been modified from its original value to Aug 8, 2012. The original email from Todd Anderson of "Anderson Law Center" to Neldon Johnson and Glenda Johnson is visible at the bottom of the PDF file. That email is dated Nov 15, 2010, which is two weeks before the letter first appeared on RaPower3.com with a date of Dec 1, 2010.
Anderson Law Center, P.C. is headquartered in Delta, UT. A picture of their corporate offices is here:
Anderson Law Center, P.C. offices
This opinion letter was authored by Tax Attorney firm Kirton-McConkie, dated Oct 31, 2012. It was addressed to Neldon Johnson of SOLCO I, LLC.
It was referred to as a "covered opinion letter" and was made available only to interested RaPower3 prospects upon request.
The first page of the letter was shown in a December 2012 video created by Jason Clement, SOLCO's "National Director of Marketing". Prior to that video, the CPA firm's identity was not disclosed.
SOLCO Video, Page 1
The letter was first published to the RaPower3.com website in November of 2013, when the website was totally revamped. That is the same time the Anderson Law Center letter (above) was [re]published.
A RaPower3 representative claimed on "Raging Bull" (an investor chat thread) that Kirton-McConkie wanted to rescind the letter after it was published. Apparently, they did not intend it to be used by anyone other than SOLCO.
The following claim appears in the letter:
The Treasury Department has made a grant under Section 1603 of the American Recovery & Reinvestment Act of 2009 with respect to the same model of solar lenses as the Solar Lenses and related equipment, which grant required a finding by the Treasury Department that such solar lenses and related equipment constituted property described in Code Section 48(a)(3)(A)(i) or (ii).
However, there is no record of a business entity known to be affiliated with IAS/RaPower3 being awarded that grant. The *official* Treasury Department documentation where all awards are listed is here:
Treasury Department Section 1603 Awards
The Kirton-McConkie letter is here:
Kirton-McConkie CPA letter/memorandum