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y <br />of tie City of Colton to each owner of property, described in the assessment, as <br />appears upon the tax rolls current at the time -of mailing., of a notice notifying <br />the owner of the amount due'and the date when payment is due and stating that <br />the payment is subject to penalty if not paid on or prior to the due date. The <br />mailing shall be made at least 15 days before each respective 15th day of April. <br />and October immediately preceding the. July 2 and January 2 dates on which cou- <br />pon payments are due to the bondholder. <br />SECURITY: Each Bond is secured by the unpaid assessment upon the lot <br />or 'parcel of land described therein, which unpaid assessment <br />constitutes alien upon the property so described: Should default be made in the <br />annual payment of the principal .or in any payment of interest by the owner of the <br />lot or parcel of land assessed, or anyone on behalf of the owner. the holder of the <br />Bond is entitled to cause foreclosure proceedings to be instituted pursuant to law. <br />The lien of the unpaid assessment is subordinate to all fixed special assess- <br />ment liens previously imposed upon the same property, but has priority over all <br />fixed special assessment liens which may thereafter be created against the property. <br />Such lien is coequal to and independent of the lien for general taxes. There are <br />prior fixed special assessment liens on the properties assessed in these proceedings. <br />NEITHER THE CITY OF COLTON NOR ANY OFFICER THEREOF IS LIABLE FOR <br />THE PAYMENT OF THE PRINCIPAL OF AND INTEREST DIV ANY BOND OTHERWISE <br />THAN FROM THE REDEMPTION FUND CREATED IN THE PROCEEDINGS FOR SUCH <br />BOND. For further explanation see caption "Bondholder's Rights Upon Default" <br />in the following Official Statement. <br />LEGAL OPINION: The legal opinion of F. MacKenzie Brown, Newport <br />Beach, California, approving the validity of the Bonds <br />will be provided without charge to the purchaser at the time of delivery of the Bonds. <br />Fees payable to F. MacKenzie. Brown, as Bond Counsel, are payable solely from the <br />proceeds of assessments and the Bonds; hence, such fees are necessarily contingent <br />upon the successful implementation and funding of the Project. <br />TAX EXEMPT: In the opinion of Bond Counsel, interest on the Bonds is ex- <br />empt from taxation by the United States of America under <br />present Federal income tax laws and from State of California personal income taxes <br />under existing statutes, regulations, rulings and court decisions; the Bonds are <br />exempt from all other State of California taxes except inheritance, gift and franchise <br />taxes. Interest may become taxable on any Bond held by a substantial user (or re- <br />lated person) of the facilities financed with the proceeds of the Bonds within the <br />meaning of Section 103 (b) of the 'Internal Revenue Code of 1954, as amended. <br />In the event that prior to the delivery of the Bonds the income received by <br />private holders from bonds of the same type and character shall.be declared to be <br />taxable under any Federal income tax laws, either by the terms of such laws or <br />by a ruling of a Federal income tax authority or official, which is followed by the <br />Internal Revenue Service, or by decision of any Federal Court, the purchaser <br />