Laserfiche WebLink
us without undertaking to verify such facts by independent investigation. <br />Based on the foregoing, we are of the opinion that: <br />1. The County is a political subdivision of the State of Florida and has <br />the power and authority to issue the Series 1992 Bonds. <br />2. The Ordinance and the Resolution have been duly enacted and adopted, <br />respectively, by the County and are valid and enforceable instruments. <br />3. The County is legally obligated to receive, hold and apply the Pledged <br />Funds in accordance with the provisions of the Resolution. <br />4. The Series 1992 Bonds are valid and legally binding special obligations <br />of the County and are payable from and secured by a lien upon and pledge of the <br />Pledged Funds, as and to the extent provided in the Resolution. <br />5. The Series 1992 Bonds and the income therefrom are exempt from <br />taxation under the laws of the State of Florida, except estate taxes and taxes <br />imposed by Chapter 220, Florida Statutes, on interest, income or profits on debt <br />obligations owned by corporations, banks and savings associations. <br />6. Assuming investment and application of the proceeds of the Series 1992 <br />Bonds as set forth in the Resolution and in the aforementioned non -arbitrage <br />certificate, the Series 1992 Bonds are not presently "arbitrage bonds" as <br />described in Section 103(b)(2) and Section 148 of the Code and applicable <br />regulations promulgated thereunder. <br />7. Interest on the Series 1992 Bonds (including any original issue <br />discount properly allocable to the holder thereof) is excluded from gross income <br />for purposes of federal income taxation and is not an item of tar, preference for <br />purposes of the federal alternative minimum tax imposed on individuals and <br />corporations under present statutes, regulations and judicial decisions; although <br />it should be noted that in the case of corporations (as defined for federal <br />E-4 <br />