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expressly set forth herein) to take such other actions and to <br /> execute and deliver such other documents, certificates, <br /> undertakings, agreements or other instruments as they, with the <br /> advice of counsel, may deem necessary or appropriate to effectuate <br /> the transactions contemplated by the Agreement,. the Installment <br /> Purchase Contract, the Deed of Trust and the Lease. <br /> Section 6 . The County covenants that, to the extent permitted <br /> by the Constitution and laws of the State of North Carolina, it <br /> will comply with the requirements of the Internal Revenue Code of <br /> 1986, as amended (the "Code") , as applicable to the Installment <br /> Purchase Contract except to the extent that the County obtains an <br /> opinion of nationally-recognized bond counsel to the effect that <br /> noncompliance would not result in the interest components of the <br /> (7/1 <br /> Installment Payments being includable in the gross income of the <br /> Lender or its assignees for purposes of federal income taxation. <br /> Section 7 . The County hereby represents that it reasonably <br /> expects that it and all subordinate entities thereof will not issue <br /> more than $10, 000, 000 of tax-exempt obligations (not counting <br /> private-activity bonds except for qualified 501(c) (3) bonds as <br /> defined in the Code) during calendar year 1995 . In addition, the <br /> County hereby designates each of the Installment Payments as a <br /> "qualified tax-exempt obligation" for the purposes of the Code. <br /> Section 8 . Brown & Wood, New York, New York, is hereby <br /> confirmed as special counsel to the County in connection with the <br /> execution and delivery by the County of the Installment Purchase <br /> Contract. <br /> 7 <br />