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DORSEY Se WHITNEY <br /> • $1, 210, 000 Liquor Store City of St. Anthony, Hennepin <br /> Revenue Bonds, Series 1986 and Ramsey Counties, Minnesota <br /> 2 <br /> We have not been asked and have not undertaken to <br /> review, the accuracy, completeness or sufficiency of the Official <br /> Statement or other offering material relating to the Bonds, and <br /> accordingly we express no opinion with respect thereto. <br /> Noncompliance following the issuance of the Bonds with <br /> certain requirements of the Internal Revenue Code and covenants <br /> of the bond resolution may result in the inclusion of interest on <br /> the Bonds in the federal and Minnesota gross income .of the owners <br /> thereof. <br /> Interest on the Bonds is includible. in book income and <br /> in earnings and profits for purposes of determining , the <br /> "alternative minimum taxable income" of corporations for taxable <br /> years beginning after December 31, 1986. - In the case of an <br /> insurance company subject to -the tax imposed by Section 831 of <br /> the Code, for taxable years beginning after December 31, 1986, . <br /> • the amount which otherwise would be taken into account as "losses <br /> incurred" under Section 8'32 (b) ( 5) shall be reduced by an amount <br /> equal. to 15 percent of the interest on the Bonds that• is .received <br /> or accrued during the taxable year. <br /> Dated this day of December, 1986. <br />