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<br />74 <br />Code”). In the event either the City or the Authority fails to comply with the foregoing tax covenant, interest on the 2018 Bonds may be includable in the gross income of the Owners <br />thereof for federal tax purposes retroactive to the date of issuance. See “TAX MATTERS”. <br />Secondary Market for Bonds <br />There can be no guarantee that there will be a secondary market for the 2018 Bonds or, <br />if a secondary market exists, that any 2018 Bonds can be sold for any particular price. Prices of bond issues for which a market is being made will depend upon then–prevailing circumstances. Such prices could be substantially different from the original purchase price. No assurance can <br />be given that the market price for the 2018 Bonds will not be affected by the introduction or enactment of any future legislation (including without limitation amendments to the Tax Code), or changes in interpretation of the Tax Code, or any action of the Internal Revenue Service (the <br />“IRS”), including but not limited to the publication of proposed or final regulations, the issuance of rulings, the selection of the 2018 Bonds for audit examination, or the course or result of any <br />IRS audit or examination of the 2018 Bonds or obligations that present similar tax issues as the <br />2018 Bonds. <br />IRS Audit of Tax–Exempt Issues <br />The IRS has a program for the auditing of tax–exempt issues, including both random <br />and targeted audits. It is possible that the 2018 Bonds will be selected for audit by the IRS. It is also possible that the market value of the 2018 Bonds might be affected as a result of such an <br />audit of the 2018 Bonds (or by an audit of similar obligations). <br /> <br />