Orange County NC Website
Browse       Search
4$ <br /> • Based on the foregoing,as of today and under existing law,we are of the following opinions: <br /> 1. The Bonds have been duly authorized and issued. The Bonds are legal, valid and binding <br /> obligations of the County, enforceable in accordance with their terms.The County's faith and credit <br /> are pledged for the payment of principal of and interest on the Bonds, and the County is authorized <br /> to levy and collect ad valorem taxes, without restriction as to rate or amount, on all locally taxable <br /> property to pay the principal of and interest on the Bonds. <br /> 2. Our opinion as set forth in paragraph 1 is subject to the effect(a)of bankruptcy, insolvency, <br /> reorganization, moratorium and other similar laws affecting creditors' rights, and (b) of general <br /> principles of equity,regardless of whether applied in a proceeding in equity or at law. <br /> 3. Interest on the Bonds paid by the County(a) is not included in gross income for federal in- <br /> come tax purposes and (b) is not an item of tax preference for purposes of the federal alternative <br /> minimum income tax imposed on individuals and corporations. The County's failure to comply with <br /> the Covenants could cause interest on the Bonds to be included in gross income for federal income <br /> tax purposes retroactively to the date of issuance of the Bonds. <br /> 4. Interest on the Bonds is exempt from existing State of North Carolina income taxation. <br /> We express no opinion regarding other federal or North Carolina tax consequences of the own- <br /> ership of or receipt or accrual of interest on the Bonds. <br /> Our services as bond counsel have been limited to rendering the foregoing opinion based on our <br /> review of such proceedings and documents as we have deemed necessary to evaluate the legality, <br /> validity and enforceability of the Bonds and to evaluate the status of the Bonds and the interest <br /> thereon under the federal and North Carolina tax laws referenced above. <br /> We have not made any investigation concerning the County's operations or condition. We ex- <br /> press no opinion(a)as to the County's ability to provide for payments on the Bonds, (b)as to the ac- <br /> curacy, completeness or fairness of any information that may have been relied on by anyone in <br /> making a decision to purchase Bonds, including the LGCs Official Statement with respect to the <br /> Bonds, or(c)as to any party's compliance with any terms or conditions precedent to any purchase of <br /> Bonds. <br /> This opinion is based on constitutional and statutory provisions and judicial decisions existing <br /> today. We assume no responsibility to update this opinion or take any other action with regard to <br /> changes in facts,circumstances or the applicable law. <br /> Very truly yours, <br /> (To Be Signed,"Sanford Holshouser LLF') <br /> • E-2 <br />