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ORIG.iNAL TO^IT?'CLlWK
� : Q,`�� •� CITY OF ST. PAUL couNCa �'
OFFICE OF THE CITY CLERK F��E NO
COU IL E L TI N GENERAL FORM ,
�RESENTED EY � �-L�-
COM M I551 ON E DAT�
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WHEREAS� the Council of the City of Saint Paul on December ��
4, 195�-� by unanimous vote passed Council File No. 220935 `
finding that the Saint �aul Municipal Development Authority,
Inc. � a non-profit coTporation, to be of benefit to the �
residents of the City and that the form of bonds proposed �
to� be issued by said corporation contain nothing objectionable
to the City or which in any way impose any kind of obligation�
burden or duty on said City� and that the incorporation of
said corporation and its use of such forms of bonds are �
consented to by the City Council; and . ;
WHEREA;�, United �tates Code Annotated� Vol. 2C, ` �ec. 103 - '
Interest on Certain Governmental Obligations� provides : �
" (a) General Rule - Gross income does not include
interest on . . . .
(1-) �the obligations of��any state, territory,
or possession of the IInited States, or .
any political subdivision of any of the
foregoing or of the District of Columbia;"
� �d - �
WHEREA� Revenue Ruling 63-20 (published as TIR-442) ~
. zRB 196-3. =5� �Income Exclusions" among other things pr`ovides: � �
, �
" (5) The corporation must have been approved by the
state or a political subdivision thereof, either
of which must also have approved the specific
obligations issued by the corporation." j
and f
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WHEREA'�, le tter of the IInited �tates Treasury Department '
Internal Revenue Service, Washington D. C. � under date of
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ORIGINAL TO�sITY GLERK
i� , ,•%.�� �� CITY OF ST. PAUL couNCi� ������
v OFFICE OF THE CITY CLERK F��E , NO
�
, � COUNCIL RESOLUTION—GENERAL FORM ;
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` ►RESENTED RY '
� COMMISSIONEQ DAT�
Page 2. �
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Ja.nuary 7, 1965 over the signature of John W. �. Littleton,
Director, Tax l�.iling Division, directed to the Saint Paul �
Municipal Development Authority� Inc. � stated, in part� �
"Accordingly� it is held that: . . . �
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(3) the bonds to be issued by the corporation will� k
in effect, be issued by the City of �aint Faul, `
Minnesota and accordingly are entitled to the �
exemption afforded by Section 4382 (a) (,1�) `o.f, the �
Code. The exemption applies to both t�e i;suance '
and the transfer of the bonds." ;
and ' � `
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WHEREA�� the City of ;Saint Paul� Minnesota regards the �
�aint Paul Municipal Development Authority, Inc. as a body +
corporate but not a body politic;nor a political subdivision �
of the City of Saint Paul� Minnesota, now, therefore� be it �
' ' ' " � RESOLVED, That the Council of the City of �aintY Paul� �
Minnesota hereby states that its intention in passing Council j
File No. 220935 on December 4, 1964 was not then and� is not now �
� to approve the specific obligations �r ariy obligations issued ,
or to be issued by the Saint Paul Nfunicipal Development Authority, �
Inc. , and the City Council of the City of Saint �aul, Minnesota�
specifically and expressly states that the passing of Coun.cil -
File No. 220935 does not in a.ny way approve� authorize or agree
_ . ,\ �with by express word or implication that the bonds issued or to
be issued by the Saint Paul Municipal Development Authority, Inc. `
� constitute a bond issue of the City of Saint Faul, Mirinesota or
on its behalf or a bond issue to which �he full faith and credit �
of the City of �aint Paul� Minnesota is thereto pledged. �
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COUNCILIviEN_ Adopted by the Council MAR 3 19651s-
, �
Yeas Nays i
Dalglish �AR 3 1965
Holland - roved 19—
Loss � � � �
Tn Favor -
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Peterson O �yOr
R�eee �►gain9t
Mr. President, Vavoulis - - -
ions a�s QUBLI$HEd �A� 6 ���
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