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L First Bank P~ace West <br /> <br /> Minnesota 55402 <br />liephone (612) 333-0543 <br /> tecopier (612) 333-0540 <br /> <br />leyton L. LeFevere <br />rtp. Lefler <br />ennis O'Br*en <br />JOhn E. Drawz <br /> <br />liavi~ J. Kennedy <br /> hn B. Dean <br />I;nn E. Purclue <br /> <br />R~charcl J. Schiefler <br /> <br />:artes L. LeFevere <br />foett P. Lefler lit <br />ray J. Strancl <br />~y J. Bjorkluncl <br />dohn G. K~essel <br /> <br />Iy~e Nolan <br /> ¥ L. Lavorato <br /> haet A. Nash <br /> Bt,an F. Rice <br />irraine S. Ctugg <br />S J. Thomson. Jr. <br />s M. Bt rommen <br />Ma~" C. Nielsen <br />Teny L. Hall <br />Tald H. Batty <br /> <br />i_~flet <br />Kenned,~ <br />O'Bricn k <br /> <br />$2,045,000 General Obligation <br />Improvement Bonds of 1984, Series II <br /> City of Ramsey <br /> Anoka County, Minnesota <br /> <br /> We have acted as bond counsel in connection with <br />the issuance by the City of Ramsey, Anoka County, <br />Minnesota, of its General Obligation Improvement Bonds <br />of 1984, Series II originally dated as of October 1, <br />1954, in the total principal amount of $2,045,000. For <br />the purpose of rendering this opinion we have examined <br />certified copies of certain proceedings taken by the <br />City in the authorization, sale and issuance of the <br />Bonds, including the form of the Bonds, and certain <br />other proceedings and documents furnished by the City. <br />From our examination of such proceedings and other doc- <br />uments, assuming the genuineness of the signatures <br />thereon and the accuracy of the facts stated therein, <br />and based upon laws, regulations, rulings and decisions <br />in effect on the date hereof, it is our opinion that: <br /> <br /> 1. The Bonds are in due form, have been duly <br />executed and delivered, and are valid and binding <br />general obligations of the City, enforceable in accord- <br />ance with their terms, except as such enforcement may <br />be limited by Minnesota or United States laws relating <br />to bankruptcy, reorganization, moratorium or creditors' <br />rights. <br /> <br /> 2. The principal of and interest on the Bonds <br />are payable primarily from special assessments levied <br />or to be levied on property specially benefited by <br />local improvements, but if necessary for the payment <br />thereof ad valorem taxes are required by law to be <br />levied on all taxable property in the City, which taxes <br />are not subject to any limitation as to rate or amount. <br /> <br /> 3. The interest to be paid on the Bonds is not <br />includable in gross income of the recipient for United <br />States or Minnesota income tax purposes, but is subject <br />to Minnesota taxes on banks and corporations measured <br />by income. <br /> <br /> <br />