Agenda - Council - 10/12/1993 - Laserfiche WebLink

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PROPOSED FORM OF LEGAL OPINION APPENDIX HOLMF~ & GRAVEN $2,250,000 General Obl/g~tlon T~x Inc~ment Refu~dL~g Bonds, Seres [993A City of Ano~ Count, ~esota We have acted as bond counsel in connect/on with the issuance by the Cit%. of Ramsay, Anoka County, Minnesota, of its General Obi/cation Tax Increment Refunding Bonds, Series 1993A, ov/c/.nally dated as of November 1, 1993, in the total pzSnc/pai amount of $2,250,000. For the purpose of rendering th/s op/nion we have examined certified copies of certa/n proceed/nEe taken by the City tn the authorization, sale and issuance of the Bonds, including the form of the Bonds, and certain other proceedings and documents furn/shed by the City° From our examination of such proceedings and other documents, assuming the genuineness of the signatures thereon and the accuracy of the facts stated therein and continuing compliance by the City with its covenants to comply ~lth the Internal Revenue Code of 1986, aa amended, and based upon laws, regulations, rulings and decisions in effect on the date hot. of, it is our opinion that: 1, The Bonds are in due form, have been duly executed and del/voted, and are valid and b/holing general obLigations of the City, enforceable in accordance with their terms, except as such enforcement may be Urn/ted by Minnesota or Un/ted States laws relating to bankruptcy, reorgan/zation, moratorium or trod/tots' rights. 2. The principal of and interest on :he Bonds are payable primarily from tax increments resulting from increases in the taxable value of rea/property in a tax incmement financing d/strict in the City, but if necessary for L.~e payment thereof ad va/orem rexes are requi~ed by law to be levied on all taxable property in the City, which taxes are not subject to any limitation as to rate or amount. 3. Interest to be p~td on the Bonds is not includable in &'toss income of the recApient for fede~l Lncome tax pu~oses or in taxable net ~come fo? ~esota ~come t~ pu~oses, and is not a p~fe~nce item for pu~oses of the ~mpu~on of the fede~l a]ter~tive minimum ~x, or the ~mpu~a~on of the ~eso~ Eter~tive mt.tm~ t~ ~posed on ink.duals, trusts ~nd estates, but such ~te~st is ~cludable ~ fede~ alter~tive ~um taxable income of co~o~ons, ~d ~nesom ~es on bsnkz and co~o~tions measured by ~come. We e~ress no op~on ~dtnc other fede~l or state t~ ~nsequences seeing ~th ~spect to the Bonds. The Bonds a~ not arbit~ge bonds and a~ not pEvate ac~vity bonds. We have not been asked and have not undertaken to review the acctxrscy, completeness or sufficiency of the Official Statement or other offering material relating to the Bonds, and accordingly we express no opinion with respect thereto. Dated at MinneapoL/s, M/nnesota, I-1