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<br />~ . <br /> <br />. <br /> <br />148(f)(4) (D) of the Code. For purposes of the foregoing, the <br />City is treating the City's Bonds as a loan made by the City of <br />Blaine to the City within the meaning of section 148(f) (4) (D)- <br />(ii) (II) of the Code. <br /> <br />4. Desianation of Qualified Tax-Exempt Obliaations. In <br />order to qualify the Bonds as "qualified tax-exempt Obligations" <br />within the meaning of Section 265(b) (3) of the Code, the City <br />hereby makes the following factual statements and <br />representations: <br /> <br />(a) the City's Bonds are issued after August 7, 1986; <br /> <br />(b) the City'S Bonds are not "private activity bonds" <br />as defined in Section 141 of the Code; <br /> <br />. <br /> <br />(c) the City hereby designates the City'S Bonds as <br />"qualified tax-exempt obligations" for pu;rposes of Section <br />265(b)(3) of the Code; <br /> <br />(d) the sum of the $1,012,375 of the City's Bonds plus <br />the reasonably anticipated amount of all other tax-exempt <br />obligations (other than private activity bonds, treating <br />qualified 501 (c) (3) bonds as not being private activity <br />bonds) which will be issued by the City (and all entities <br />subordinate to, or treated as one issuer with, the City) <br />during calendar year 1991 will not exceed $10,000,000; <br /> <br />(e) the sum of the $1,012,375 of the City's Bonds plus <br />the aggregate principal amount of all other obligations <br />issued or to be issued by the City during calendar year 1991 <br />which have been designated or which are anticipated to b~ <br />eligible for designation for purposes of Section 265(b){3) <br />of the Code does not and is not reasonably expected to <br />exceed $10,000,000; and <br /> <br />(f) pursuant to Section 265 (b) (3) (C) (iii) of the Code, <br />the City states that it is receiving the benefits from the <br />issuance of the $1,012,375 of the City'S Bonds and the City <br />hereby irrevocably agrees with the City of Blaine to the <br />allocation of said amount to the City for purposes of <br />Section 265{b){3) of the Code and further agrees and finds <br />that said allocation bears a reasonable relationship to the <br />respective benefits received. <br /> <br />5. Tax Levies. To provide moneys for payment of the <br />principal of and interest on the City'S Bonds, and for the <br />benefit of the owners from time to time of the City'S Bonds and <br />for the benefit of the City of Blaine in respect of its payment <br /> <br />. <br /> <br />15717 <br /> <br />4 <br />