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• <br />PRELIMINARY OFFICIAL STATEMENT DATED , 1987 <br />TWO NEW ISSUES <br />In the opinion of Piper & Marbury, Baltimore, Maryland, Co -Bond <br />Counsel, - under existing statutes, regulations and decisions, assuming <br />compliance with certain covenants described herein, interest on the Bonds of <br />each Issue is excludable from gross income for federal income tax purposes <br />except as described herein, and the Bonds of each Issue, their transfer and the <br />income therefrom, including any profit made on the sale thereof, shall at all <br />times be free from taxation of every kind by the State of Florida or any local <br />unit, political subdivision or other instrumentality of the State of Florida, <br />except taxes imposed by Chapter 220, Florida Statutes on interest income or <br />profits on debt obligations owned by corporations. As described herein, the <br />interest on the Bonds of all Issues may be subject to certain other taxes. See <br />"Tax Exemptions" herein. <br />$1,990,000 <br />Bonds of various Florida Issuers, each designated <br />Variable Rate Demand/Fixed Rate <br />Industrial Development Revenue Refunding Bonds <br />(Florida Convalescent Centers, Inc, Project) <br />$4,800,000 <br />Indian River County <br />Series 1988A <br />Initial interest rate through <br />198: <br />Due: January 1, 2011 <br />Reference date of each Issue: <br />$3,190,000 <br />Polk County Industrial <br />Development Authority <br />Series 1987 <br />Initial interest rate through <br />198_ <br />Due: January 1, 2011 <br />Price of each Issue: <br />The Bonds of each Issue are limited obligations of the Issuer thereof <br />payable solely from payments to be made under a separate Loan Agreement between <br />such Issuer and Florida Convalescent Centers, Inc. (the "Company"). The Bonds <br />of each Issue are secured by a separate Letter of Credit issued by <br />,Ex F F i 8 7- <br />