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er <br />4. <br />in and for Indian aealsCounty, <br />therefromFlorida, <br />has expiredlwithout.anyd <br />the time for takingg appeals <br />appeal being taken. <br />LEGALITY <br />The issuance of the Notes is subject to the approval of <br />Rhoads & Sinon, Boca roving opinion, innsubstantiallythe <br />theCounty, <br />whose unqualified app <br />attached hereto as Appendix B will be available at the time o <br />delivery of the Notes. Certain legal matters will be passed upon <br />Attorney, and <br />for the County by Charles P. Vitunac, Esq., County <br />for the Underwriters by Ballard, Spahr, Andrews & Ingersoll, <br />Washington, DC. <br />NEW FEDERAL TAX LEGISLATION <br />The Internal Revenue Code of 1986 <br />ent of On October 22, 1986, the Presid <br />nated as HhR.U3838a 99th <br />signed into law a tax reform bill designated The Tax Reform <br />Congress, 2nd Session (the "Tax Reform Bill"). revises <br />Bill, as signed into law by the President, substantially <br />the <br />income <br />tax law rred as the oInt the <br />United <br />evenuestates, <br />eIofc1986." Asrawresult <br />refBill, <br />Technic <br />however, ReformaB <br />of numerous errors in the printing of <br />fethe TCongress is currently <br />he Internal Revenue Code of 1986. <br />Corrections Bill to amend t <br />Numerous provisions of the Internal <br />bonds venue Code oand <br />1986 affect the issuers of state and local government <br />art of the County to comply with any one or more <br />notes such as the Notes described in this Official Statement. <br />Failure pr the p respect to the Notes will render interest <br />of such provisions with <br />on the Notes includible in the gross income of the owners thereof <br />federal income tax, retroactively to the date the <br />for purposes of issued. Among those provisions are more <br />Notes were originally ag investment of funds treated as <br />of <br />restrictive rules conNotes <br />("arbbitrage"), advance refunding an <br />P1 of the Notes (1 establishment of reserve funds and <br />tax-exempt obligations, <br />application of Note proceeds to benefit private activities. The <br />be require <br />to 'rebate" to the <br />ed <br />County is also required to file an information return with <br />respect to the issue and may Profits on an ongoing basis <br />federal government certain arbitrage <br />issue. Under the terms of the <br />throughout the term of the <br />these provisions will apply <br />Internal Revenue Code of 1986, <br />generally to all state and local government obligations issued <br />after September 1, 1987• <br />27 <br />