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• <br /> Bonds of this series have been designated by the <br /> Issuer as "Qualified Tax Exempt Obligations" pursuant to <br /> Section 265(b) of the Internal Revenue Code of 1986 . <br /> IT IS HEREBY CERTIFIED, RECITED, COVENANTED AND AGREED <br /> that all acts, conditions and things required by the <br /> Constitution and laws of the State of Minnesota to be done, to <br /> exist , to happen and to be performed preliminary to and in the <br /> issuance of this Bond in order to make it a valid. and binding <br /> general obligation of the Issuer in accordance with its terms , <br /> have been done, do exist , have happened and have been performed <br /> as so required; that in and by the Resolution, the Issuer has <br /> covenanted and agreed with the holders of any of said Bonds <br /> that it will impose and collect, or cause to be imposed and <br /> collected, charges for the service, use and availability of the <br /> System at the times and in the amounts required to produce net <br /> revenues adequate with other pledged funds to pay the accreted <br /> amounts when due on the Bonds of this series, but the full <br /> faith and credit and taxing powers of the Issuer have been <br /> pledged to the payment of said accreted amounts when due, and <br /> ad valorem taxes , if necessary for such purpose, will be levied <br /> upon all taxable property in the Issuer , without limitation as <br /> to rate or amount ; and that this Bond, together with all other <br /> • indebtedness of the Issuer outstanding on the date hereof and <br /> on the date of its actual issuance and delivery, does not <br /> exceed any constitutional or statutory limitation of <br /> indebtedness . <br /> (Form of certificate to be printed on the reverse side of <br /> each Bond, following a full copy of the legal opinion) <br /> We certify that the above is a full , true and correct <br /> copy of the legal opinion rendered by bond counsel on the issue <br /> of Bonds of the City of St . Anthony, Minnesota., which includes <br /> the within Bond, dated as of the date of delivery of and <br /> payment for the Bonds . <br /> (Facsimile Signature) (Facsimile Signature) <br /> City Manager Mayor <br /> -9- <br />