71-89 Anticipation Notes $75K Park Improvements

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Notes are delivered to it. That opinion will include an opinion, based upon and assun~Lng compliance w~th 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 bonds" 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 - 1989 Renewal are being issued in anticipation of bonds for the purpose of acquiring and improving real estate for a municipal park. The Off-Street Parking Improvement Bodd Anticipation Notes - 1989 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 - 1989 Renewal are being issued in anticipation of bonds for the purpose of constructing and renovating storm and sanitary sewer lines and any necessary appurte- nances thereto. The Fire Truck Acquisition Bond Anticipation Notes are being issued in anticipation of bonds for the purpose of paying the costs of acquiring a fire truck and all 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 type~ritten or xerographically reproduced form at the expense of the City. If the original purchaser requests printed Notes, the original purchaser smst pay the ~xpense 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 expense of the original purchaser may be made. It is anticipated that delivery will be made approximately on December 15, 1989. The original purchaser must pay for the Notes on the date of delivery in Federal Reserve Funds of the United States of America. If the original purchaser has purchased the Notes for reoffering to the public, the ori$inal purchaser viii be required to provide to the City, prior to the delivery of the Notes, the initial offering price of each maturity of the Notes to the public (excluding bondhouses, brokers and other intermediaries), which prices shall be expressed as a dollar amount (the "initial offering prices"). Regardless of whether the original purchaser has purchased the Notes for reoffering or for holding for its account, the original purchaser will be required to provide to -2-