This opinion responds to a request from Representative Phil Pankey on an issue related to House Bill 96-1100. The bill would provide for the refunding of revenues in excess of the Arveschoug-Bird statutory limitation on state general fund appropriation. The refund is accomplished through a state income tax credit for the 199 6 income tax year. The bill also amends section 24-77-102(4), C.R.S. which defines "expenditure" for purposes of the Taxpayer Bill of Rights ("TABOR"), article X, section 20(2)(E), Colo. Const.