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nsrm ,P- "'e°°''"`c -. —.nn Via' � � 4a`�•. <br />i�s1°iri • �f�YSt�uuto 9 � - ' <br />January 29, 2016 <br />Mr. Carl Cecil <br />Liberty National Bank <br />305 Lamar Ave. <br />Paris, Texas 75460 <br />Re: Lessee's Counsel Opinion <br />Gentlemen: <br />As Interim City Attorney of the City of Paris, Texas ( "Lessee "), I have examined a duly <br />executed original of the Municipal Lease Agreement dated as of January 28, 2016 (the <br />"Agreement "), between Lessee and Liberty National Bank ( "Lessor ") and the <br />proceedings taken by Lessee to authorize and execute the Agreement. Based upon <br />such examination of law and fact as I have deemed necessary or appropriate for <br />purposes of the opinions set forth below, I am of the opinion that: <br />1. Lessee is a "qualified small issuer" for the 2016 calendar year within the meaning <br />of Section 265(b)(C)(3) the Internal Revenue Code of 1986, as amended (the <br />"Code "). <br />2. The interest component of the rental payments as set forth in the Schedule of <br />Payments executed pursuant to the Agreement is exempt from Federal income <br />tax under Section 103 of the Code, and from franchise and ad valorem taxes of <br />the State of Texas. <br />3. The Agreement has been duly authorized, executed and delivered by Lessee <br />pursuant to all necessary constitutional, statutory and governing body approvals. <br />4. The Agreement is a legal, valid and binding obligation of Lessee, enforceable <br />against Lessee in accordance with its terms, subject to principles of <br />governmental immunity, bankruptcy, insolvency, reorganization, moratorium, <br />liquidation and other similar laws now or hereafter enacted relating to creditors' <br />rights generally or by principles of equity which permit the exercise of judicial <br />discretion. <br />P.O. BOX 9037 • PARIS, TEXAS 75461 -9037 • (903) 785 -7511 • FAX (903) 785 -8519 <br />MISM II <br />