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't <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 />4. Designation of Qualified Tax-Exempt Obligations. 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 />(a) the City's Bonds are issued after August 7, 1986; <br />(b) the City's Bonds are not "private activity bonds" <br />as defined in Section 141 of the Code; <br />(c) the City hereby designates the City's Bonds as <br />"qualified tax-exempt obligations" for purposes of Section <br />265(b) (3) of the Code; <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 />(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 be <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 />(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 />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 />• 15717 <br />4 <br />