86-88 Park improvement BAN $100,000

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after maturity, and if such an award would result in tie proposals, the successful proposal will be selected by lot in a manner determined by the Director of Finance. Any informality or failure to conform to the instructions herein contained may be waived by the Director of Finance, and the Director of Finance may reject any or all of the proposals presented. Legal matters incident to the issuance of the Notes and with regard to the tax-exempt status of the interest thereon are subject to the approv- ing legal opinion of Calfee, Halter & Griswold, Bond Counsel, which will be furnished without cost to the original purchaser at the time the Notes are delivered to it. That opinion will include an opinion, based upon and assuming compliance with covenants and the accuracy of repre- sentations and certifications of the City, that under the existing law (a) the interest on the Notes (i) is excluded from gross income for federal income tax purposes under the Internal Revenue Code of 1986, as amended (the "Code"), (ii) is not treated as an item of tax preference for purposes of the alternative minimum 'tax imposed on individuals and corporations by the Code, and (iii) is exempt from the Ohio .personal income tax and excluded from the net income base of the Ohio corporate franchise tax, and (b) the Notes are not "private activity bon~s" as defined in the Code. Under the Code, the interest may be subject to alternative minimum, environmental, and branch profits taxes imposed on certain corporations, and to a tax imposed on excess net passive income of certain S corporations. For a more complete discussion of tax aspects, see the enclosed Preliminary Official Statement. The Park Improvement Bond Anticipation Notes - 1988 Renewal are being issued in anticipation of bonds for the purpose of acquiring and improv- ing real estate for a municipal park. The Off-Street Parking Improvement Bond Anticipation Notes - 1988 Renewal are being issued in anticipation of bonds for the purpose of acquiring, clearing and improving real estate for off-street parking of motor vehicles. The 1988 Sewer Improvement Bond Anticipation Notes are to be issued in anticipation of bonds for the purpose of constructing and renovating storm and sanitary sewer lines and any necessary appurtenances thereto. The Notes, unless paid from other sources and subject to the provisions of federal bankruptcy law and other laws affecting creditors' rights, are to be paid from the proceeds of the levy of ad valorem taxes on all property subject to ad valorem taxes levied by the City, which taxes are within the ten-mill limitation imposed by law. The Notes will be prepared in typewritten or xerographically reproduced form at the expense of the City. If the original purchaser requests printed Notes, the original purchaser must pay the expense of printing. Delivery will be made without charge at such place in the State of Ohio as the original purchaser shall designate, provided that other mutual satisfactory arrangements for delivery outside the State of Ohio at the -2-