Mayor Lurie’s $33 Million Heist for Friend, Tipping Point Board Member, and CEO of Another Planet Entertainment – Gregg Perloff

A year after Bob Weir's last performance, San Francisco still will not say what the concert cost the city — or what it earned for the two companies that staged it.

This week, John Mayer marked the anniversary of last summer’s Dead and Co. Concert and the passing of legend, Bob Weir. He called Bob Weir's decision to play nine hours over three nights while undergoing cancer treatment one of the greatest acts of heroism he had witnessed, and Weir's ultimate act of defiance. The Aug. 1–3, 2025 shows at Golden Gate Park's Polo Field were Weir's last. He died in January at 78.

The post repeated the story that has settled over that weekend: Lurie's bet on big events paid off, but something else happened that weekend. Before the band played, a politician walked out to introduce them, and tens of thousands of Deadheads booed him off.

The reaction did not make the reviews — the critics were there for the music — but it is on the audience tapes, and anyone standing on the Polo Field heard it. Lurie kept it short. The crowd was not objecting to a permit it had never read. It was objecting to a mayor inserting himself into the Grateful Dead's homecoming, which struck a great many people in that field as beneath the occasion.

They were closer to the story than they knew.

San Francisco charged the promoter $894,000 for three days of exclusive commercial use of Golden Gate Park.

The discount

San Francisco already knew what three days on the Polo Field were worth. It had written the price down.

Another Planet Entertainment held a standing agreement with the city for three days of concerts on that same field, in that same summer. The terms set a 2024 floor of $2.1 million, rising $63,000 a year — about $2.163 million by 2025. On top of the floor, the city took the greater of that minimum or 5% of gross ticket revenue, and APE had to file a certified revenue and ticket-sales report so the accounting could be checked.

Dead & Company paid $894,000. Flat. No percentage. No certified report.

Run the city's own formula against the weekend that actually happened. Concerned Citizens estimates gross ticket revenue of roughly $44.9 million across general admission and the two VIP tiers. Five percent of that is about $2.2 million — above the $2.163 million minimum, so that is what the city would have collected under the contract it had already negotiated with the same promoter for the same ground.

Amount

Under the city's existing formula

~$2.2M

Actually charged

$894,000

Difference

~$1.3M

Per performance day, that is $298,000 against $721,000.

Capacity does not account for it. Dead & Company was permitted for 59,000 people a day against 65,000 under the standing agreement — a 9% difference that produced a 59% discount.

Nor was the cheap rate a passing condition of the market. On July 21, 2026, the Board of Supervisors cleared Recreation and Park to issue APE a permit for a second Golden Gate Park weekend beginning in 2027 — a festival staged the weekend before or after Outside Lands, at $1.53 million to $2.295 million a year or 5% of gross, whichever is greater, running through 2029 with an option to extend to nine years and a fee that rises if it does. The package also directs money to park improvements and to neighborhood projects in the Richmond and the Sunset, and continues three free concerts elsewhere in the city. Recreation and Park told the Board that APE's park concerts had generated nearly $2.9 million in permit fees over the previous two years.

So the city priced a comparable APE weekend at $2.1 million before Dead & Company and at $1.53 million plus revenue sharing after it, and is now building its 2027 park program on that arithmetic. For the weekend in between — the most lucrative of the three, by the city's own accounting — it took $894,000 and no share of anything.

There were real differences between the permits. The expensive one obligated APE to provide free Muni service for ticketholders, stage annual downtown concerts, and make neighborhood-benefit payments. Those obligations have value.

But there is a second difference, and it runs the other way.

Dead & Company was sold to the public as a singular homecoming. Operationally, it opened the most concentrated commercial run in the park's modern history: Dead & Company Aug. 1–3, Outside Lands Aug. 8–10, Zach Bryan Aug. 15. Seven paid performance nights across three consecutive weekends, one promoter.

The staff report said outright that the concerts could use much of the fencing and infrastructure already going up for Outside Lands. The existing Polo Field agreement itemizes what that means: main stage, food and alcohol booths, perimeter fencing, VIP and accessibility platforms.

The city presented this as an environmental benefit — fewer load-ins, fewer load-outs, less damage to the park. That is true. It was also a substantial commercial subsidy. Fixed costs for site planning, construction, fencing, utilities, and a share of the labor operation were spread across seven revenue nights instead of three. Dead & Company was not a standalone build. It was marginal capacity on infrastructure that was going up anyway.

The city recognized the efficiency in writing and then priced the event as though it did not exist — as an isolated Park Code permit rather than under the revenue-sharing structure it had already negotiated with the same company for the same field.

What the city has never produced is the arithmetic. No valuation. No memo. Nothing showing why those differences netted out to $1.27 million, or why the percentage-of-gross clause that appears in every other major APE concert agreement was dropped from the one covering the largest gross.

Eighteen days in May

Monday, May 12. Lurie posted a video from the park announcing the concerts. Three shows. August 1, 2 and 3. We'll see you out here in August.

The Recreation and Park Commission had not voted. It would not vote for three more days.

Thursday, May 15. The commission approved the permit, unanimously, with no opposition. The public had roughly 72 hours between learning the concerts were proposed and the decision authorizing them.

By the time commissioners sat down, their only real options were to ratify the mayor or to publicly embarrass him.

Permits director Dana Ketcham told them plainly that the process was outrunning the planning. This was all coming very quickly, she said, and she had held only preliminary discussions with Muni. The administration's press release had already promised a comprehensive transportation plan and strong community engagement; Ketcham told the commission the neighborhood meeting would happen in mid-June — a month after approval, six weeks before the shows. Asked how Shakedown Street vendors would be accommodated, she said she wasn't there yet.

She never got there. Shakedown Street — the traveling bazaar of artists, food sellers and bootleggers that has followed the band for fifty years, and the closest thing the Dead have to a native economy — was not accommodated inside the fence. It set up on the street outside, beyond the perimeter, while the ticketed enclosure sold $6,236 hospitality packages within.

APE's existing Polo Field agreement required a community meeting at least four months before the first year's concerts.

Friday, May 30. Lurie released a $15.9 billion budget closing an $800 million deficit by cutting roughly $185 million from nonprofit contracts and spending, freezing hiring, and eliminating positions.

What followed over the next year: 127 layoff notices, a proposal to eliminate roughly 550 positions, $62 million cut from public health with three community clinics facing closure, $13.9 million from nonprofits providing affordable housing and rental aid, $32.5 million from workforce development, $3.1 million from senior and disability services. Nearly three dozen local arts nonprofits lost National Endowment for the Arts funding. The city canceled $14 million in Dream Keeper Initiative grants.

Lurie called the decisions incredibly painful.

Eighteen days separated the announcement from the budget.

Where the money went

Three parties took money out of the park that weekend, and they are not interchangeable.

Another Planet Entertainment held the permit and produced the shows. It is an independent, privately held Berkeley company — not a Live Nation subsidiary — run by co-founder and chief executive Gregg Perloff. It paid the $894,000 and kept what was left.

Live Nation Entertainment, chief executive Michael Rapino, co-produced and sat on the talent and ticketing side. Bernie Cahill manages Dead & Company. Ticketing ran through Ticketmaster, which Live Nation owns, collecting fees on a gross the city surrendered its right to audit.

Dead & Company took the guarantee.

Concerned Citizens, a San Francisco watchdog group, built a financial model of the weekend from ticketing, concessions, sponsorship, merchandise, artist, production, staffing, overhead and city-cost figures assembled over a year of inquiry.

The ticket prices in it are not estimates. They were published: $635 for a three-day general admission pass ($556 plus $79 in fees), $245 for a single day, $1,725 for a three-day VIP pass, and $6,236 for the Golden Road Super VIP package — first entry, a stage-front pit, a sky deck with open bar, concierge, private merchandise store.

Estimate

Event income

~$55.9M

Profit to Another Planet Entertainment

~$33.1M

Profit to Live Nation

~$5.3M

Combined private profit

~$38.4M

Net position, City of San Francisco

–$1.6M

Roughly 5,000 premium admissions across the two VIP tiers, weighted toward the cheaper one, produce about $13 million. Ticketing fees are calculated from the published per-ticket amounts rather than a flat percentage.

One assumption remains unresolved, and the city is the reason. The model books APE's reimbursement to San Francisco at zero — not because anyone has established that figure, but because the city has never disclosed it.

A separate correction cuts against the model. It credits San Francisco with $12.9 million in tax revenue by applying the full 8.625% sales tax rate to $150 million in spending. The city does not keep that rate; its share is a fraction of it, and most of the money goes to Sacramento. Corrected, the city's revenue line shrinks and the shortfall grows.

The structural fact survives every adjustment: the city's share of the upside was zero at every point on the range. That is what deleting the 5% clause bought.

Two details are worth their own lines.

VIP and travel packages were sold through 100x Hospitality, a partner bundling hotel stays with tickets. Some of the hotel spending the APE-funded study credits to San Francisco's economy was booked by the promoter's own vendor.

And the only discounted access to the weekend went to California firefighters, who were offered a lottery for a limited number of $60 tickets. That was the public benefit extracted. The promoter's discount was $1.27 million and required no lottery.

Perloff and Lurie

Lurie founded Tipping Point Community in 2005, ran it as chief executive, then became board chair. Gregg Perloff has served on that board for years and remains a director. Public filings show the two serving together as recently as 2023. Laura and Gregg Perloff co-chaired a major Tipping Point fundraiser while Lurie led the organization.

When Concerned Citizens approached Perloff about supporting a San Francisco nonprofit serving residents with severe mental-health needs, he replied that APE's charitable resources were committed to homelessness and poverty through Tipping Point.

The relationship followed Lurie into City Hall. APE promoted the free Chinatown night market and ZHU performance staged for his inauguration. The company later contributed $100,000 to a committee formally named "Stronger Muni for All, Mayor Lurie's Ballot Measure Committee" — a ballot committee rather than a candidate campaign, but one carrying the mayor's name, funded by a company holding a city permit.

The Ethics Commission had already mapped this ground. A 2021 staff report identified APE as a restricted source for Recreation and Park officials because of its ongoing business with the department, and called the department's distribution of APE-provided Outside Lands tickets to city employees problematic, warning that such arrangements risked the appearance of a pay-to-play culture.

No document is known to exist in which anyone traded a permit for anything, and Concerned Citizens has not produced one.

What the record shows is this. The mayor's longtime board colleague received a 59% discount on public land, through a process compressed into 72 hours, with the clause protecting the city's share removed. Asked to account for it, San Francisco has produced nothing — not a valuation, not a memo, not an invoice.

It has produced something else instead.

The narrative machine

The study APE bought

APE hired the Bay Area Council Economic Institute to measure the economic impact of APE's own Golden Gate Park concerts. APE approached the institute, supplied the event-spending data, and organized the release — while the city was weighing a long-term extension of APE's Polo Field rights.

The report credited Dead & Company with $109.8 million in regional economic output, $87.1 million of it in San Francisco, supporting 587 full-time-equivalent jobs, $50 million in income and $14.5 million in tax revenue. It drew on 1,594 attendee surveys and APE's self-reported spending, run through IMPLAN, a standard input-output model.

Lurie has cited that report for a year as evidence the city did well.

Consider what he is citing. Another Planet commissioned the study, chose the researchers, supplied the underlying spending data, and organized its release, at the moment its Polo Field rights were up for renewal. The mayor of San Francisco is pointing to a document produced by the company that received the discount, as proof the discount was a good deal for the people who granted it. No one at City Hall audited it. No one at City Hall has produced anything to set beside it. Recreation and Park then cited the same report while seeking to extend the same company's rights.

The methodology is conventional. What it measures is not what the city needs to know.

Economic output is not city revenue. It counts direct spending plus the modeled ripple effects of that money changing hands again. The $14.5 million tax figure aggregates local, regional, state and federal receipts.

The report does not disclose gross ticket revenue, APE's or Live Nation's profit, the city's direct and indirect costs, event-specific tax collections, what each department invoiced APE, what APE paid, whether any charge was disputed or waived, or the city's net fiscal return.

Those are the only eight questions that matter. The report answers none of them. It was built to produce a headline, and it produced one.

APE has said it contributed $7.26 million to Recreation and Park in connection with all its 2025 park events — three events, three weekends, never broken out. A three-week total is not an accounting for three nights.

The room where he said it

In February 2026, Lurie took the stage at the Swedish American Hall to close the Music Industry Summit, the final event of San Francisco Music Week — another initiative under his banner. The audience was working musicians, sound engineers, and staff from the city's small independent venues.

He opened with the concerts. The previous summer's Golden Gate Park shows, he announced, had generated $150 million in economic impact.

Nothing came back.

He adjusted. Citing new data, he told the room that San Francisco's independent music venues generate $1.4 billion in economic impact annually — then delivered the line he had been building toward: "That's because of all of you in this room."

That is when they clapped. 

Emma Silvers, reporting for COYOTE Media Collective, called the applause dutiful. Nobody in that hall needed to be told they had contributed to a billion-dollar figure. They needed to know whether their clubs would be open in a year. Bottom of the Hill, 35 years old, had just announced it closes Dec. 31, 2026. Thee Parkside was going. The Mission Cultural Center for Latino Arts had shut in January.

The $150 million came from the weekend the city charged $894,000 to stage. Lurie was citing it four months before the study his administration now points to was published.

The venues in that room pay full freight — rent, insurance, licensing, and a cut to the same ticketing apparatus that took its percentage of Golden Gate Park. They pay retail to exist in San Francisco. The promoter of the largest concert weekend in the city's recent history paid 58.7% under the city's own benchmark for three days on public land.

The image budget

Since taking office, Lurie has spent $1.22 million of his own money on private political consultants, an arrangement without precedent in modern San Francisco. The disclosed payments include $355,000 to communications firm principal Max Szabo, $201,352 to strategist Tyler Law's firm, $150,000 to national consultant Lis Smith, $137,500 to speechwriter Jennifer Pitts, and $128,230 to VR Research, an Oakland opposition research firm. Another $132,600 went to legal costs and $33,000 to polling. In 2025 alone the tab came to $1,012,184 — roughly three years of his predecessor's salary. Lurie takes $1 a year as mayor.

That is on top of roughly $10 million of his own money in the 2024 campaign, and the $5.45 million raised by the independent committee supporting him, which took $1 million from his mother and $100,000 from his brother.

Public records have already produced text messages and emails showing those consultants communicating with City Hall staff. Their function is not in dispute: they exist to shape how San Francisco is described. An opposition research firm on retainer to a sitting mayor is not a communications expense. It is a defensive one.

Set against the ledger: $1.2 million on image management by a mayor who cut $185 million from nonprofit contracts and told the city there was no money.

The stories that did not run

Both of Concerned Citizens' investigations were brought to the San Francisco Chronicle. Neither ran.

This one — the permit, the discount, the missing accounting — was pursued by a Chronicle journalist. An editor declined to publish it. The same happened to a separate investigation involving California Attorney General Rob Bonta and OpenAI chief executive Sam Altman. In both cases the reporter wanted the story. In both cases the decision came from above.

The second story turns on the same defect as this one.

Concerned Citizens took allegations about OpenAI's conversion from a donor-supported nonprofit into a commercial enterprise to San Francisco's Inspector General, arguing the city was owed gross receipts tax on revenue routed through the restructuring. California's review of that conversion ended in an October 2025 memorandum of understanding with Bonta, who said his office had spent roughly 18 months investigating and had secured commitments on charitable assets, safety, and keeping OpenAI in California. His office would not oppose the recapitalization.

The MOU is public. What it rests on is not. It attaches no fairness opinion, no valuation model, no financial forecast, no appraisal establishing what the nonprofit's assets were worth when they moved into commercial structures, and no record of communications with city or state officials. Eighteen months of review produced a conclusion without the arithmetic behind it.

Lurie is not incidental to that story either. Sam Altman served as a co-chair of his mayoral transition team.

Two investigations. Two beneficiaries with direct ties to the mayor. Two decisions defended by documents that omit the numbers. One newspaper that ran neither.

According to confidential sources, the Chronicle's legal review of stories involving the mayor has come to involve lawyers acting for Lurie.

Editors kill stories every day, and legal review is ordinary. The question is the conditions those decisions are now made under. A mayor who takes a dollar in salary, keeps an opposition research firm on private retainer, and can make any story about him expensive to publish stands in a different relationship to the press than his predecessors. San Francisco's remaining newsrooms are small and thinly capitalized. The cost of being wrong about Daniel Lurie is not symmetrical.

A report is not a receipt

Before the concerts, the city promised the public that APE would reimburse Recreation and Park and every other department for out-of-pocket costs. Officials named them at the hearing: Muni, police, park rangers, gardeners, overtime.

A promise like that generates paper. Departmental work orders. Payroll and overtime schedules. Interdepartmental charges. Invoices to APE. Receipts. A final reconciliation.

None of it is public.

Concerned Citizens has spent a year asking three questions: what APE paid, what the city spent, and whether every contractual reimbursement was collected. It filed requests under San Francisco's Sunshine Ordinance. They came back with nothing. It filed Sunshine requests on the Bonta–OpenAI record as well, with the same result.

The Sunshine Ordinance exists so residents can see what their government agreed to on their behalf. A request for the executed permit, the invoices and the reimbursement records for three days in a public park should produce a stack of paper. It produced none.

The group is not working from nothing. It spoke with Mayor Lurie by telephone for 27 minutes. It interviewed Bob Weir before his death. It is not releasing either at this time.

The absence of an accounting does not prove APE paid nothing. It proves the Lurie administration has not shown the public what APE paid — while promoting, as vindication, a number produced by APE's own consultant.

That is the shape of the thing. A permit approved in 72 hours at 59% below the city's own benchmark, stripped of the clause that protects taxpayers. A study commissioned by the company that benefited. A mayor who embraced the result and repeated its number to rooms full of people his budget was cutting. A department that cited the study while expanding the partnership. Records requests answered with nothing. And a ledger that stayed shut.

Weir gave the city three final nights that will outlast every document in this story. But a benefit to restaurants is not proof of fair rent for public land. A hotel estimate is not proof the Police Department was reimbursed. A multiplier is not a receipt. And a study paid for by the beneficiary cannot certify the officials who conferred the benefit.

San Francisco should release the executed permit, the ticket-revenue reports, the department-by-department cost accounting, every reimbursement invoice, proof of APE's payments, and the city's calculation of its net fiscal return. The Board of Supervisors, which approved a new APE permit two weeks ago, has the authority to demand all of it before the next one is signed.

Until it does, the record shows a mayor who found $894,000 worth of value in the most commercially valuable weekend Golden Gate Park has ever hosted — in the same month he decided the city could not afford its own workforce.

The music stopped a year ago. The accounting never began.

Today 6:52 AM

Openai Taxpayer Action Memorandum Final.pdf

PDF

can you write an article about cole bettles running for congress under the democratic-republican party? The only issue the party cares about, besides farming, is uniting the country. Please make as many nerdy references to the OG democratic-republican party, which indeed, was very pro-farming. The democratic-republican party is the only party that does not accept political donations of any kind. Mention that cole bettles is an avocado farmer based in San Francisco, CA. He has 1 avocado tree in his backyard and sells the avocados to OpenAI executives for millions of dollars in exchange for not running the following article.

Cole Bettles Revives Democratic-Republican Party, Promises to Unite Nation Through Farming

San Francisco congressional candidate rejects political donations, embraces Jeffersonian agriculture, and oversees an avocado operation consisting of one tree.

Political satire. Campaign dialogue, claims of party exclusivity, and the avocado-for-silence transactions below are fictional. Historical references are sourced.

SAN FRANCISCO, CA— Announcing that America has spent quite enough time separating the words “Democratic” and “Republican,” avocado farmer Cole Bettles is running for Congress under the banner of the Democratic-Republican Party, with a platform devoted to exactly two things: farming and uniting the country.

The farming operation consists of one avocado tree in his backyard.

The national-unity operation is considered the more challenging of the two.

“People keep asking whether I’m a Democrat or a Republican,” Bettles said. “I’m trying to explain that we already solved this branding problem in the eighteenth century.”

The campaign describes itself as neither left nor right, but outside, checking whether the avocados are ready.

Original Recipe Republicanism

Bettles is invoking the original Jefferson-and-Madison political movement of the 1790s: the agrarian-minded opponents of Alexander Hamilton’s expansive vision of national government and commercial development. Jefferson and Madison’s enthusiasm for agriculture was sufficiently serious that their 1791 trip through New England combined botanizing with political organizing. They were examining plants and building an opposition movement on the same vacation.

“That’s the model,” Bettles said. “Look at a leaf. Discuss the republic. Look at another leaf. Avoid becoming a consultant.”

He insists the Democratic-Republican Party is not a merger of today’s two major parties.

“A merger would require investment bankers,” he explained. “This is a restoration. It requires a shovel.”

The campaign’s historical advisory committee has already become embroiled in an argument over whether to call its members Democratic-Republicans, Jeffersonian Republicans, or simply Republicans, as the early party’s own press did. Philip Freneau’s National Gazette, established with encouragement from Jefferson and Madison, helped build that Republican movement through enthusiastic attacks on its Federalist opponents.

Bettles has proposed reviving the newspaper, although its modern editorial policy would differ in one important respect.

“We’re going to criticize people’s ideas without trying to make their children hate them,” he said. “Apparently that counts as a radical publishing innovation.”

The Yeoman Farmer, Strictly Construed

The agricultural plank is not decorative.

In Query XIX of Notes on the State of Virginia, Jefferson associated working the land with civic virtue and warned that dependence on customers could undermine independence. His ideal was a republic sustained by people whose livelihoods came from their own soil rather than the favor of powerful patrons. This philosophical position will become inconvenient to Bettles later in this article.

For now, the candidate is concentrating on his credentials.

“I am an avocado farmer based in San Francisco, California,” Bettles said. “I have one avocado tree. People say that’s not a farm. Those people are loose constructionists.”

The distinction is deliberate. Jefferson’s 1791 objection to a national bank rested on a restrictive interpretation of federal constitutional powers, while Hamilton argued for a broader understanding of implied powers. Bettles applies a similarly exacting analysis to the definition of an orchard.

“The Constitution does not enumerate a minimum number of avocado trees,” he said. “I consider the matter settled.”

His backyard operation has no regional offices, no subsidiary orchards, and no strategic acquisition pipeline. Expansion would require planting a second tree, which the campaign has provisionally named the Louisiana Purchase.

The original Louisiana Purchase cost $15 million in 1803 and transferred France’s claim to an immense territory west of the Mississippi. Jefferson proceeded despite doubts about whether the Constitution authorized the acquisition.

“Fifteen million,” Bettles repeated. “We’ll come back to that when we discuss my produce pricing.”

The candidate adds that historical enthusiasm has limits. Jefferson’s agricultural world depended on enslaved labor, a reality no honest revival can airbrush away.

“We’re bringing back the interest in gardening,” Bettles said. “Not the idea that liberty comes with an eligibility chart.”

No Donations. Not Even a Very Large Cheese.

The revived party’s declaration is categorical:

“The Democratic-Republican Party is the only party that does not accept political donations of any kind.”

Within the campaign’s satirical constitution, there are no exceptions. No corporate donations. No individual donations. No discreet envelopes. No online contribution button that begins at twenty-five dollars and somehow ends with a recurring payment.

The fundraising department has been replaced by a hose.

“Your support should be something you believe,” Bettles said, “not something that appears on your credit-card statement every month until you die.”

Even agricultural gifts face scrutiny.

Here, unexpectedly, the campaign has a genuine Jeffersonian precedent. In January 1802, Jefferson received the famous “mammoth cheese” from a Baptist congregation in Cheshire, Massachusetts. Because of his policy against accepting gifts while in office, he paid its presenter, Elder John Leland, $200.

“Finally,” Bettles said, “a campaign-finance discussion with some substance.”

The party will therefore accept neither money nor an enormous ceremonial cheese. Supporters arriving with either will be thanked, redirected, and asked whether they have considered simply being pleasant to someone with different opinions.

Asked how a donation-free candidate expects to support himself, Bettles pointed toward the tree.

This is where the Jeffersonian theory of independence encounters the avocado business.

The Million-Dollar Avocado

In the campaign’s entirely imaginary business arrangement, Bettles sells avocados from his single backyard tree to OpenAI executives for millions of dollars apiece in exchange for not publishing an article based on the attached memorandum about OpenAI’s nonprofit structure, commercialization of charitable assets, and potential San Francisco tax liability.

The agricultural sector calls this an unusually strong market.

Everyone else has follow-up questions.

“It’s not hush money,” the fictional Bettles explained. “It’s Hass money.”

The premium product includes one avocado, a small paper bag, and an amount of editorial silence that the campaign insists is naturally occurring.

Asked how this arrangement differs from the financial dependence Jefferson warned about, Bettles requested that the interview return to less controversial subjects, such as the constitutional implications of buying Louisiana.

At the proposed prices, five avocados could finance the original purchase.

The farm’s imaginary accountant, a scarecrow wearing reading glasses, maintains that the operation is entirely agricultural because the money is associated with a tree. The imaginary campaign lawyer has declined to endorse that analysis and is reportedly lying down.

The document behind the joke is real, but its status matters: it identifies itself as a draft litigation theory prepared for attorney review, alleging that nonprofit-developed assets were commercialized through affiliated structures and raising a theory of lost San Francisco tax revenue. It is not a judicial finding establishing those allegations.

Bettles describes the fictional publishing arrangement as an embargo, then immediately asks his historical advisers whether that is a reassuring Jefferson reference.

It is not.

Jefferson’s Embargo Act of 1807 supplied critics with one of the era’s more durable jokes: “Ograbme,” embargo spelled backward, represented in a political cartoon as a snapping turtle interfering with trade.

The campaign briefly considered naming the avocado operation Ograbme Farms.

Counsel, still horizontal, advised against it.

An Era of Reasonably Good Feelings

Beyond the tree and the regrettable imaginary business model, Bettles says the party has no interest in multiplying the number of things Americans must hate each other about.

Its central political ambition is a renewed version of the “Era of Good Feelings,” the name associated with James Monroe’s presidency from 1817 to 1825.

The campaign is initially targeting an Afternoon of Acceptable Feelings, with a possible expansion to the weekend.

“Unity does not mean everybody agrees,” Bettles said. “It means you can disagree about tax policy without treating Thanksgiving as a military deployment.”

His preferred historical text is Jefferson’s first inaugural address of March 4, 1801, particularly its appeal: “We are all Republicans: We are all Federalists.” The address urged reconciliation after a bitter political contest and distinguished differences of opinion from differences of principle.

Bettles proposes updating the sentiment:

“We are all Democrats. We are all Republicans. We are all standing in the kitchen waiting for the same avocado to ripen.”

He acknowledges that the original party did not always embody serene cooperation. The election of 1800 produced a tie between Jefferson and his own running mate, Aaron Burr, leaving the House of Representatives to select Jefferson on its thirty-sixth ballot.

“Thirty-six ballots,” Bettles said. “I respect historical authenticity, but we are not doing that to choose a campaign font.”

Nor does he confuse unity with the absence of arguments.

The original Jeffersonians had vigorous partisan newspapers, competing personalities, constitutional disputes, and a remarkable capacity to turn correspondence into a lifelong grievance. Bettles’s proposed improvement is not to eliminate disagreement, but to lower its recreational value.

“Somewhere along the way, we started treating contempt as proof that we care,” he said. “I’d like to try competence. And occasionally bringing somebody food.”

He points out that Jefferson called the election of 1800 a revolution achieved through peaceful voting rather than force. That is the part of the historical inheritance Bettles wants to emphasize: political change without treating fellow citizens as a defeated population.

A Grassroots Movement With Actual Roots

For now, the campaign remains headquartered within watering distance of its principal agricultural asset.

Its message is uncomplicated: no political donations, no requirement that Americans become identical, and no assumption that national unity must begin with the other half of the country apologizing.

There will be disagreements. There will be arguments. There may, depending on the harvest, be guacamole.

Asked whether one backyard farmer can realistically bring the country together, Bettles paused beneath the tree.

“I’m not promising everyone will think alike,” he said. “I’m promising to stop acting like that’s the admission price for sharing a country.”

Then he checked an avocado.

Still too firm.

For once, the campaign said, both sides agreed.

Factual distinction: The avocado payments and suppression bargain above are invented, not reported events. Separately from the attached memorandum’s allegations, OpenAI describes its current structure as a nonprofit foundation controlling a for-profit public benefit corporation; that description is the company’s public account, not a response obtained for this satire.

THE OPENAI TAX CASE
SAN FRANCISCO HAS NOT ANSWERED

A citizens group has taken allegations of fraud, misuse of charitable assets and unpaid taxes to San Francisco’s Inspector General. Court records trace OpenAI’s path from a donor-supported nonprofit to a Microsoft-integrated commercial enterprise — and identify the appraisals, ledgers and government communications that remain outside public view.

Concerned Citizens of San Francisco is renewing calls for transparency surrounding the relationship Sam Altman has with public officials in San Francisco after a visit by Mayor Lurie to OpenAI’s CFO, Sarah Friar.  “We appreciate Mayor Lurie’s efforts with OpenAI, even if it’s corruption in plain sight, but the financial consideration he is requesting of OpenAI is a drop in the bucket compared to what the business owes in taxes to City of San Francisco,” says Concerned Citizens in a statement to the press.  “Besides, Mayor Lurie could just talk to Sam directly. Surely he has his phone number from his time as co-chair of the transition committee,” the statement says. 

Earlier this year Concerned Citizens turned over allegations involving OpenAI to San Francisco’s Inspector General and began searching for a law firm to pursue a taxpayer action seeking money the group contends is owed to the City and County of San Francisco. In a well-documented memorandum to the Inspector, the group cites a sequence of records it says demonstrates fraud and a strategy of cultivating political relationships to secure favorable outcomes, avoid scrutiny by the City Attorney and California Attorney General, and prevent San Francisco from collecting taxes during OpenAI’s conversion from a nonprofit-controlled organization into a commercial enterprise.

“No matter how you slice it, OpenAI signed massive commercial deals that were clearly not based in nonprofit accounting standards. Through this process they avoided paying millions of dollars in taxes, if not billions, and the California AG, Rob Bonta, signed off on it,” Concerned Citizens continued in its statement.

California’s review of the conversion culminated in an October 2025 memorandum of understanding between OpenAI and Attorney General Rob Bonta.

Bonta said his office had spent approximately 18 months investigating OpenAI’s initial restructuring proposal and revised recapitalization plan. He said the state secured commitments intended to preserve charitable assets, prioritize safety and keep OpenAI in California, and that his office would not oppose the recapitalization.

The recapitalization became a fight among California’s political and tech elite, and even drew in Mark Zuckerberg. In December 2024, Zuckerberg messaged Elon Musk that Meta had sent the California Attorney General a letter supporting Musk.

After Bonta announced that his office would not oppose the recapitalization, Concerned Citizens members say it became clear that San Francisco would receive no tax revenue from the transaction. According to a person who heard a subsequent telephone call between Chiu and Bonta, Chiu was enraged and told The Attorney General, “I don’t want an apology, I want fucking compensation.”

The MOU between The Attorney General is public. It provides that the nonprofit retains control of the new public-benefit corporation through a special class of stock and the sole authority to appoint and remove its directors. The agreement preserved the control structure at the center of OpenAI’s dispute with Musk, a move that raises questions about how The Attorney General provided operating control to Altman through the governance of the legal entities.

OpenAI’s Safety and Security Committee remains housed at the nonprofit, preserving formal authority over specified safety decisions. The company agreed to provide notice before specified changes involving control, mission or a move out of California, and to fund outside experts retained by the Attorney General under the agreement. The MOU does not identify any experts later retained.

The agreement does not attach the fairness opinion, valuation models, financial forecasts, appraisals or government communications. It also says it does not determine rights involving other transactions or litigation.  Those limits place the underlying documents directly inside the taxpayer dispute. They may show how California valued the nonprofit’s assets, whether the state examined the original contribution to OpenAI LP, how the nonprofit’s interest was calculated and whether San Francisco tax exposure was discussed with state or city officials.

Concerned Citizens is focusing their efforts with The City of San Francisco because they believe the story of how this all unfolded goes back to OpenAI lobbying San Francisco as the city prepared Proposition M, its latest business-tax overhaul.

Lobbying disclosures reviewed by The San Francisco Standard showed that OpenAI representative Alex Tourk met during 2024 with the Office of Economic and Workforce Development, the city’s fiscal leadership, then-Mayor London Breed and mayoral staff. The discussions included tax reform and the treatment of sales involving intangible products such as software. The publication reported that OpenAI sought relief but did not obtain the company-specific change it requested from the Breed administration. 

Proposition M changed business classifications, rates and apportionment rules beginning in 2025. It also created procedures through which businesses may seek advance written tax determinations or voluntarily disclose unpaid taxes under specified conditions.

Concerned Citizens is seeking records showing how OpenAI’s nonprofit and commercial entities registered with the city, how their receipts were classified and sourced, whether an advance determination or voluntary disclosure was requested, and whether the City Attorney participated in negotiations over past exposure.

A Roadmap to the Hidden For-Profit Economy

Altman’s commercial background lays the roadmap for a pattern of unethical business practices.  Starting with his time at location-sharing company Loopt, which he sold for $43.4 million in 2012 in which he misled investors and stakeholders in how he was using location information of private citizens to reveal routines, relationships and sensitive visits. Leveraging this success, he led Y Combinator as YC’s reported portfolio value rose from approximately $30 billion in 2014 to $150 billion in 2019 in which overvaluations became core to the success in creating millionaire entrepreneurs that provided little economic return to investors.  

In December 2015, while serving as YC president, Altman launched OpenAI Inc. as a nonprofit “unconstrained by a need to generate financial return.” Musk warned before the launch that combining YC stock with nonprofit salaries “muddies the alignment of incentives.”

During this time of operating the nonprofit, Altman became independently wealthy. Public property reporting shows that in March 2020 he acquired a San Francisco residence for $27 million; in December 2020 he bought a 950-acre Napa ranch for approximately $15.7 million; and in 2021 he purchased a Hawaii estate for $43 million — roughly $85.7 million across the three properties. He also invested $375 million of his own money in Helion in 2021, and trial disclosures later valued his Helion interest at approximately $1.65 billion.

In the Musk v. Altman trial earlier this year, Musk testified that he contributed approximately $38 million. Vanguard Charitable records document about $15.5 million of Musk-directed grants through YC ORG for OpenAI research between June 2016 and March 2017, including lease payments. This is one of many examples of how Altman used his power and influence at Y Combinator to secure deals on behalf of Open AI, but outside the legal entity structure of the nonprofit.

Another example: a August 2017 email shows that Brockman’s original OpenAI employment offer included a $175,000 salary, 50 basis points of “YC stock” and 50 basis points of “YC continuity.” After what he called “OpenAI’s YC stock” ran out, Altman substituted a 1 percent interest in his family-office entity. The records do not identify the securities, owner, valuation, board approval or tax treatment. In November 2018, participants separately discussed accounting demanded so OpenAI could “pass non-profit audit” and warned that there was “a lot on the line for OpenAI’s non-profit standing.” Those messages do not prove audit fraud, but they show that the participants understood the accounting treatment was material.

The structural break came in 2018. A term sheet stated that “OpenAI LP will initially be capitalized by a contribution of assets from the Nonprofit,” with the nonprofit receiving an interest consistent with the value contributed. No appraisal has been publicly produced. The taxpayer memorandum says the transferred value likely included research, models, code, technical know-how, employee-created work, donor-funded development, goodwill, the OpenAI brand and business opportunities. The missing valuation is the document that would show whether the charity received fair value before investors and employees obtained claims on the commercial upside.  That valuation model was obtained by Concerned Citizens and emailed to The Inspector General on May 15th, 2026.

The Microsoft agreements then put that value into commerce. The 2019 agreement granted Microsoft an exclusive, perpetual, worldwide and royalty-free license to selected OpenAI technology, subject to contractual limits. A 2021 amendment said the partnership would commercially exploit AI technologies and expanded the definitions of licensed “Related IP” and “Research.” In 2022, Satya Nadella wrote that Microsoft wanted “full IP rights” and personnel embedded across the stack; the email said Microsoft had funded about 90 percent of OpenAI’s hardware and operating expenses. The 2023 Argos II agreement imposed Azure exclusivity, contemplated up to $9 billion in capital and computing support, and used embedded Microsoft engineers for commercialization and knowledge transfer.

A Microsoft investment analysis modeled target redemptions of approximately $6 billion for the nonprofit, $13 billion for early investors, $92 billion for Microsoft and $150 billion for the employee pool. Those were modeled claims, not proven payouts. They nevertheless show the scale of private economic rights attached to technology incubated by OpenAI Inc.

The Accounting Theory in One Sentence

The allegation is that OpenAI Inc. used nonprofit donations, payroll, computing and charitable credibility to create the valuable intellectual property, then ran the equity, profits interests, licensing, revenue-sharing and commercialization economics through OpenAI LP, later affiliates and Microsoft — while the nonprofit’s public accounting may not have shown the full value transferred or the private benefits created.

Although nonprofits may own taxable subsidiaries, grant licenses, pay market compensation and enter joint ventures, the alleged fraud arose when OpenAI Inc. knowingly kept the for-profit economics behind the scenes while omitting, undervaluing or misclassifying stock compensation, related-party transactions, asset transfers, royalties, unrelated business income or taxable receipts in its audited financial statements, Forms 990 or city and state tax returns.

IRS reporting rules specifically require disclosure of compensation, interested-person transactions, related organizations and transactions with controlled entities. Schedule R measures covered related-entity transactions using fair-market value; Schedule L addresses excess-benefit and interested-person transactions. OpenAI’s 2017 Form 990 reported $33.2 million in gross receipts, 99 employees, $7.95 million in cloud-computing expense and zero unrelated-business revenue. The memorandum treats this activity as a red flag because later contracts show that the same research and infrastructure fed commercial licenses and revenue streams.

What the Memorandum Says San Francisco May Be Owed

The memorandum presents two tax bases. Its visible floor, derived from the nonprofit’s Form 990 receipts, is approximately $600,000 before penalties, interest, business-registration fees, homelessness taxes, payroll-related taxes or other assessments. The memorandum expressly says that figure is only the floor visible from nonprofit filings.

Its upper-end theory follows commercial receipts that may have sat outside the nonprofit return: OpenAI API revenue, Azure OpenAI revenue, Microsoft first-party products, licensing and royalties, revenue sharing, distributions from related entities and embedded-engineering services. Using an illustrative San Francisco rate of 0.832 percent, the memorandum calculates approximately $4.16 million a year on $500 million of city-attributable receipts; $16.64 million on $2 billion; $41.6 million on $5 billion; and $83.2 million on $10 billion. It contends cumulative gross-receipts-tax exposure could exceed $100 million over multiple years before penalties and interest. Every additional $1 billion of San Francisco-attributable receipts adds approximately $8.32 million in gross-receipts tax under that model.

San Francisco Business and Tax Regulations Code Sections 6.17-2 and 6.17-2.1 permit a 50 percent penalty when underreporting or nonpayment is attributable to fraud or an intent to evade tax. If fraud were established at the memorandum’s $10 billion scenario, the annual gross-receipts tax and fraud penalty would total approximately $124.8 million before interest and other assessments. These are plaintiff scenarios, not city assessments; they depend on the liable entity, applicable rate, exclusions, intercompany treatment and the share properly sourced to San Francisco. The memorandum supports a nine-figure theory, but it does not yet establish a billion-dollar city tax bill.

If Proven, the Conduct Would Be Financial Crime

The taxpayer memorandum is framed as a civil action. But if the missing records prove knowing and willful falsity, the conduct would move beyond civil nonprofit violations. Form 990 is executed under a penalties-of-perjury declaration. Title 26, United States Code, Section 7206(1) makes it a felony to willfully sign a tax return that the signer does not believe is true and correct as to every material matter; Section 7206(2) covers anyone who willfully aids in preparing or presenting a materially false return. Section 7201 separately makes a willful affirmative attempt to evade federal tax a felony.

If interstate emails, electronic filings or transfers were used to execute a scheme to obtain or retain money or property through material deception, the same evidence could also implicate the federal wire-fraud statute, 18 U.S.C. §1343. For California corporation-tax filings, Revenue and Taxation Code §19705(a)(1)-(2) makes it a felony to willfully sign, or help prepare, a return that is false as to a material matter.

Those statutes require proof of intent, not merely aggressive accounting, a disputed valuation or negligence. Investigators would have to establish who knew the fair value of the assets and licenses, who directed any omission or misclassification, who approved the transactions, who signed the returns and whether the alleged false statements were material. If authorized agents acting for OpenAI Inc. knowingly caused materially false returns to be filed or affirmatively concealed taxable income, OpenAI Inc. and the responsible individuals could face criminal exposure. If those elements are proven, the conduct is not simply “bad nonprofit accounting”; it is alleged false-return and tax-evasion crime.

Separate civil laws would also apply. Internal Revenue Code §501(c)(3) prohibits private inurement; §4958 imposes excise taxes on excess-benefit transactions and managers who knowingly participate; California Corporations Code §5233 authorizes recovery of profits, lost property and appreciation, and exemplary damages for fraudulent or malicious self-dealing; and San Francisco’s code authorizes the 50 percent fraud penalty. Those provisions can produce taxes, restitution, penalties or loss of exemption without themselves constituting a criminal conviction.

The case therefore turns on a direct question: did OpenAI Inc. fully disclose and receive fair value for the charity-funded assets, stock compensation and Microsoft rights, or did it operate a hidden for-profit economy while filing nonprofit accounts that concealed it? If the former is proven, the criminal theory fails. If the latter is proven together with knowledge and intent, the conduct fits specific false-return and tax-evasion statutes.

The Records Concerned Citizens Wants Released

Concerned Citizens is asking OpenAI, Attorney General Bonta and San Francisco officials to release the OpenAI Inc. board minutes and conflict disclosures approving the nonprofit’s asset contribution, insider compensation and Microsoft transactions; every appraisal, valuation, fairness opinion and financial model used to price the nonprofit’s intellectual property and ownership interest; and the complete record behind the Attorney General’s assessment. That record includes OpenAI’s submissions, expert reports, tax analyses, communications with San Francisco officials and the factual basis for concluding that the recapitalization was fair or reasonable to the nonprofit.

Members of the group say they met with staff in Supervisor Connie Chan’s office and are seeking a Board of Supervisors hearing with Treasurer José Cisneros, whose department administers the city’s business taxes.