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1 <br /> n <br /> DOBSEY 8c WHITNEY z <br /> r.. <br /> i <br /> $405,000 Liquor Store Revenue City of St. Anthony, Hennepin and <br /> Refunding Bonds, Series 1992A Ramsey Counties, Minnesota <br /> estates and trusts; and (d) is includable in adjusted current earnings of corporations <br /> in determining alternative minimum taxable income for purposes. of the federal <br /> alternative minimum tax imposed on corporations. <br /> 4. The City has designated the Bonds as "qualified tax-exempt <br /> obligations" within the meaning of Section 265(b)(3) of the Code, and financial <br /> institutions described in Section 265(b)(5) of the Code may treat the Bonds for <br /> purposes of Sections 265(b)(2) and 291(e)(1)(B) of the Code as if they were acquired on r; <br /> August 7, 1986. <br /> LJ <br /> The opinions expressed in paragraphs 3 and 4 above are subject to the <br /> condition of the City's compliance with all requirements of the Code that must be <br /> satisfied subsequent to the issuance of the Bonds in order that interest thereon may '+ <br /> be, and continue to be, excluded from gross income for federal income tax purposes <br /> and that the Bonds be and continue to be .qualified tax-exempt obligations. The City <br /> has covenanted to comply with these continuing requirements; its failure to do so <br /> could result in the inclusion of interest on the Bonds in federal gross income and in <br /> Minnesota taxable net income, retroactive to the date of issuance of the Bonds: <br /> Except as stated in this opinion, we express no opinion regarding federal, state or <br /> other tax consequences to holders of the Bonds. <br /> We have not been asked and have not undertaken to review the <br /> accuracy, completeness of sufficiency of any offering materials relating to the Bonds, <br /> and accordingly, we express no opinion with respect thereto. <br /> Dated this day of October, 1992. <br /> 1-2 <br />