Opinion of Bond Counsel. On the Issue Date, the Authority, the Bank, the Placement Agent and the Trustee shall have received the opinion of Bond Counsel to the effect that, inter alia : (a) interest income on the Bonds is not includable in gross income under the Code except for those tax consequence set forth therein; (b) interest income on the Bonds is not includable as gross income under the New Jersey Gross Income Tax Act (P.L. 1976, Chapter 47); (c) the offering of the Bonds is not required to be registered under the Securities Act of 1933, as amended, or under the rules and regulations promulgated thereunder; and (d) the Bonds have been duly authorized and issued under the provisions of the Indenture, the Resolution and the Act.
Appears in 2 contracts
Samples: Loan Agreement (Burlington Coat Factory Warehouse Corp), Loan Agreement (Burlington Coat Factory Warehouse Corp)
Opinion of Bond Counsel. On As a condition precedent to the Issue Dateissuance of the Bonds, the Authority, the Bank, the Placement Agent Authority and the Trustee Purchaser shall have received the opinion of Bond Counsel to the effect that, inter alia :
(a) interest income on the Bonds is not includable in gross income for federal income tax purposes under the Code except for those tax consequence set forth thereinCode;
(b) interest income on the Bonds or gain from the sale thereof is not includable as gross income under the New Jersey State Gross Income Tax Act (P.L. 1976, Chapter 47);
(c) the offering or sale of the Bonds is not required to be registered under the Securities Act of 1933, as amended, or under the rules and regulations promulgated thereunder; and
(d) the Bonds have been duly authorized and issued under the provisions of the Indenture, the Resolution and the ActAct and constitute valid, binding special and limited obligations of the Authority and are enforceable in accordance with their terms.
Appears in 1 contract
Samples: Bond Agreement
Opinion of Bond Counsel. On the Issue Date, the Authority, the Bank, the Placement Agent and the Trustee shall have received the opinion of Bond Counsel to the effect that, inter alia alia:
(ai) interest income on the Bonds is not includable in gross income under the Code except for those tax consequence consequences set forth therein;
(bii) interest income on the Bonds is not includable as gross income under the New Jersey Gross Income Tax Act (P.L. 1976, Chapter 47);
(ciii) the offering of the Bonds is not required to be registered under the Securities Act of 1933, as amended, or under the rules and regulations promulgated thereunder; and
(div) the Bonds have been duly authorized and issued under the provisions of the Indenture, the Resolution and the Act.;
Appears in 1 contract
Samples: Letter of Credit and Reimbursement Agreement (Burlington Coat Factory Warehouse Corp)