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(2) an opinion from bond counsel that such transfer (i) is permitted <br /> under Section 10 of Ordinance No. 1433-88 of the City, and (ii) shall not cause interest on <br /> any of the 1993 Bonds or Refunded 1988 Bonds to become subject to federal income tax. <br /> The City reserves the right to substitute other securities for the Acquired Obligations in <br /> the event it may do so pursuant to Section 148 of the federal Internal Revenue Code of 1986 and <br /> applicable regulations thereunder, upon compliance with the following conditions: <br /> (1) The securities to be substituted are direct obligations of, or obligations the <br /> principal of and interest on which are unconditionally guaranteed by, the United States of <br /> America. <br /> (2) The City obtains a verification by a certified public accounting firm which <br /> shall be satisfactory to bond counsel and the City that such securities bear such interest <br /> and mature at such times and in such amounts as to fully replace the Acquired Obligations <br /> for which they are substituted, and to provide, together with Acquired Obligations and <br /> cash remaining, for the payment of the amounts specified in items (a) and (b) above. <br /> (3) The City obtains an opinion from bond counsel that such substitution (i) is <br /> permitted under Section 10 of Ordinance No. 1433-88 of the City, and (ii) shall not cause <br /> interest on any of the 1993 Bonds or Refunded 1988 Bonds to become subject to federal <br /> income tax. <br /> B. Disposition of 1993 Bond Proceeds and Interfund Transfers. The proceeds <br /> of the 1993 Bonds shall be deposited as follows: <br /> (1) There shall be deposited with the Refunding Trustee and credited to <br /> the 1993 Advance Refunding Fund an amount sufficient, together with the amounts stated <br /> in paragraphs 12.B.(i) and (ii) below, and any necessary beginning cash balance, to <br /> provide for the purchase of the Acquired Obligations for the advance refunding and <br /> defeasance of the Refunded 1988 Bonds (in accordance with this ordinance, the Escrow <br /> -32- Fww01EDOc 93/10/26 <br />