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qualified the Bonds as tax - exempt under the Internal Revenue Code <br />of 1986, as amended. <br />(a) Taxable Status of the Bonds. It is hereby <br />determined that the Bonds are to be issued as fully taxable <br />obligations, and all interest received on the Bonds is to be <br />included in the gross income of the Holder of any Bond for <br />federal income taxation purposes and, to the same extent, in both <br />gross income and taxable net income for state income taxation <br />purposes. <br />(b) Payment of Issuance Expenses. The City authorizes <br />the Purchaser to forward the amount of Bond proceeds allocable to <br />the payment of issuance expenses to Resource Bank & Trust <br />Company, Minneapolis, Minnesota on the closing date for further <br />distribution as directed by the City's financial advisor, Ehlers. <br />(c) Severability. If any section, paragraph or <br />provision of this resolution shall be held to be invalid or <br />unenforceable for any reason, the invalidity or unenforceability <br />of such section, paragraph or provision shall not affect any of <br />the remaining provisions of this resolution. <br />(d) Headings. Headings in this resolution are <br />included for convenience of reference only and are not a part <br />hereof, and shall not limit or define the meaning of any <br />provision hereof. <br />The motion for the adoption of the foregoing resolution <br />was duly seconded by member and, after a full <br />discussion thereof and upon a vote being taken thereon, the <br />following voted in favor thereof: <br />and the following voted against the same: <br />adopted. <br />1094077.1 <br />Whereupon said resolution was declared duly passed and <br />Page 133 <br />