MD455470
MD455470
$17,145,000
CITY OF STOW, OHIO
VARIOUS PURPOSE LTGO
BOND ANTICIPATION NOTES
MIG1
FINANCIAL DATA
City of Stow, Ohio
(Per OMAC 3/29/07)
General Obligations
Limited Tax
Bonds $5,355,000 $5,355,000
Notes $15,145,000 $15,145,000
Security: The notes shall be full general obligations of the City and the full faith, credit and revenue of the City are
hereby pledged for the prompt payment of the same. The par value to be received from the sale of the bonds
anticipated by the Notes and any excess funds resulting from the issuance of the Notes shall, to the extent necessary,
be used only for the retirement of the Notes at maturity, together with interest thereon, and is hereby pledged for
such purpose.
Purpose: To retire, with cash on hand, $19,445,000 Notes due 5/10/07 and proved new money of $5,000,000 issued
for the purpose of (i) constructing, furnishing and equipping a service maintance center and parks maintenance and
urban forestry center and improving the sites therefore, (ii) constructing furnishing and equipping two fire stations,
improving the sites therefore and acquiring any necessary real estate therefore, (iii) acquiring fire trucks and
rescue/fire vehicles, (iv) acquiring from the County of Summit, Ohio the water distribution system serving the City,
(v) improving the City’s waterworks system by acquiring and installing replacement water meters and related
metering equipment and constructing a fixed network automated radio water meter reading system, together with all
necessary appurtenances thereto, and (vi) paying a portion of the costs of constructing, furnishing, equipping and
otherwise improving a new Stow Municipal Court facility and equipping and improving its site.
The statements contained in this circular and those on any subsequent page of same, while not guaranteed, are official or founded on information regarded as reliable. They
are the data upon which we purchased these securities. All offerings are made subject to prior sale and change in price.
2
ASSESSED VALUATION
Years Total Personal Tangible Real Estate Public Utility
2005-2006 852,819,860 48,981,900 793,775,470 10,062,490
2004-2005 786,732,900 49,694,290 725,984,290 11,054,320
2003-2004 770,725,650 54,198,280 705,653,810 10,873,560
Next Reappraisal 1998-1999
TAX EXEMPTION
In the opinion of Bond Counsel for the Notes, based upon an analysis of existing laws, regulations, rulings
and court decisions, interest on the Notes, except on Notes while held by any Substantial User or Related Person,
each as defined in the Internal Revenue Code of 1986, as amended, or the 1954 Code, as appropriate, is excludible
from gross income for Federal income tax purposes. Bond Counsel for the Notes also of the opinion that interest on
the Notes is not a specific item of tax preference under Section 57 of the Internal Revenue Code of 1986 (the
“Code”) for purposes of the Federal individual or corporate alternative minimum taxes. Furthermore, Bond Counsel
for the Notes is of the opinion that interest on the Notes is exempt from taxation, including personal income
taxation, by the State of Ohio and its political subdivisions, and is excludible from the net income base used in
calculating the Ohio corporate franchise tax.
The Code imposes various restrictions, conditions, and requirements relating to the exclusion from gross
income for Federal income tax purposes of interest on obligations such as the Notes. The Issuer has covenanted to
comply with certain restrictions designed to ensure that interest on the Notes will not be includable in gross income
for Federal income tax purposes. Failure to comply with these covenants could result in interest on the Notes being
includable in income for Federal income tax purposes and such inclusion could be required retroactively to the date
of issuance of the Notes. The opinion of Bond Counsel assumes compliance with these covenants. However Bond
Counsel has not undertaken to determine (or to inform any person) whether any actions taken (or not taken) or
events occurring (or not occurring) after the date of issuance of the Notes may adversely affect the tax status of the
interest on the Notes.
Certain requirements and procedures contained or referred to in the resolution authorizing the Notes and
other relevant documents may be changed and certain actions (including without limitation, defeasance of the Notes)
may be taken or omitted under the circumstances and subject to the terms and conditions set forth in such
documents. Bond Counsel expresses no opinion as to any Notes or the interest thereon if any such change occurs or
action is taken or omitted upon the advice or approval of bond counsel other than Squire, Sanders & Dempsey LLP.
Although Bond Counsel for the Notes has rendered an opinion that interest on the Notes is excludible from
gross income for Federal and Ohio income tax purposes, the ownership or disposition of, or the accrual or receipt of
interest on, the Notes may otherwise affect a Noteholders Federal, state or local tax liabilities. The nature and extent
of these other tax consequences may depend upon the particular tax status of the Noteholder or the Noteholders
other items of income or deduction. Bond Counsel expresses no opinions regarding any tax consequences other than
what is set forth in its opinion and each Noteholder or potential Noteholder is urged to consult with tax counsel with
respect to the effects of purchasing, holding or disposing the Notes on the tax liabilities of the individual or entity.
For example, corporations are required to include all tax-exempt interest in determining Adjusted current
earnings under Section 56 (c) of the Code, which may increase the amount of any alternative minimum tax owed
under Section 59 of the Code, which is based on the alternative minimum taxable income of any corporation subject
to that tax. Ownership or disposition of the Notes may result in other collateral Federal, state or local tax
consequence for certain taxpayers, including without limitation, increasing the federal tax liability of certain foreign
corporations subject to the branch profits tax imposed by Section 884 of the Code increasing the federal tax liability
of certain insurance companies, under Section 832 of the Code, increasing the federal tax liability and affecting the
status of certain S Corporations subject to Sections 1362 and 1375 of the Code, and increasing the federal tax
liability of certain individual recipients of Social Security or Railroad Retirement benefits, under Section 86 of the
Code. Ownership of any Notes may also result in the limitation of interest and certain other deductions for financial
institutions and certain other taxpayers, pursuant to Section 265 of the Code. Finally, residence of the holder of
Notes in a state other than Ohio or being subject to tax in a state other than Ohio, may result in income or other tax
liabilities being imposed by such states or their political subdivisions based on the interest or other income from the
Notes.
300 Mercantile Library Bldg.
414 Walnut Street
Cincinnati, Ohio 45202-3910
SEASONGOOD & MAYER, LLC
SPECIALISTS IN PUBLIC FINANCE SINCE 1887 (513) 621-2000
Toll Free 1-800-767-7207
The statements contained in this circular and those on any subsequent page of same, while not guaranteed, are official or founded on information regarded as reliable. They
are the data upon which we purchased these securities. All offerings are made subject to prior sale and change in price.