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Assist the City in presenting information to bond rating <br />organizations and providers of credit enhancement relating to legal <br />issues affecting the issuance of the Bonds. <br />g. Such other and further services as are normally performed by bond <br />counsel in connection with similar financings. <br />h. Bond Disclosure training for staff and Council. <br />Attorneys' Bond Opinion will be delivered by Attorneys on the date the Bonds are <br />exchanged for their purchase price (the "Closing"). <br />The Bond Opinion will be based on facts and law existing as of its date, will cover <br />certain matters not directly addressed by such authorities, and will represent Attorneys' <br />judgment as to the proper treatment of the Bonds for federal income tax purposes. <br />Attorneys' opinion is not binding on the Internal Revenue Service ("IRS") or the courts. <br />Attorneys cannot and will not give any opinion or assurance about the effect of future <br />changes in the Internal Revenue Code of 1986 (the "Code"), the applicable regulations, <br />the interpretation thereof or the enforcement thereof by the I RS. City acknowledges that <br />future legislation, if enacted into law, or clarification of the Code may cause interest on <br />the Bonds to be subject, directly or indirectly, to federal income taxation, or otherwise <br />prevent owners of the Bonds from realizing the full current benefit of the tax status of <br />such interest. The introduction or enactment of any such future legislation or clarification <br />of the Code may also affect the market price for, or marketability of, the Bonds. <br />Attorneys will express no opinion regarding any pending or proposed federal tax <br />legislation. <br />In rendering the Bond Opinion, Attorneys will rely upon the certified proceedings <br />and other certifications of public officials and other persons furnished to Attorneys <br />without undertaking to verify the same by independent investigation, and Attorneys will <br />assume continuing compliance by the City with applicable laws relating to the Bonds." <br />Page 10 of 10 <br />REV: 01-26-1715 <br />ATTV/AGR/2017.019/JONES HALL WATER BOND REFUNDING 2017 <br />