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38 <br /> =BIHTT A <br /> CERTIFICATE REGARDING QUALIPICATION TENDER CERTAIN <br /> PROVISIONS OP TEE INTERNAL REVENUE CODE <br /> January , 1995 <br /> NationsDank of North Carolina, N.A. <br /> P.O. Box <br /> Chapel Hill, North Carolina <br /> RB; g_9`0;_OQO.00 Piaigrol g Facri_1 ty <br /> Dear Sirs: <br /> The County of Orange, a. political subdivision and body politic <br /> of the State of North Carolina (the "County") , is or will be the <br /> principal user of certain improvements to be constructed on real <br /> property owned by the County and financed with the proceeds of the <br /> credit facility described above (the "Facility") . This certificate <br /> is furnished to: (i) NationsBank of North Carolina, N.A. (the <br /> "Dank") , in its capacity as the lender pursuant to the Facility <br /> under that certain Installment Purchase Contract (the 'Contract") , <br /> dated as of January , 1995, by and between the County and the <br /> Bank, and (ii) _ , in their capacity as bond <br /> counsel in connection with the issuance of the Facility, for <br /> purposes of their opinion as to the exemption from Federal income <br /> tax of the interest portion oe payments due to the Bank pursuant to <br /> the Facility. This certificate is being executed by <br /> _.._..___ who is County Manager of the County and who <br />