- 44 - 515 U.S. ___, ___, 115 S. Ct. 2159, 2163 (1995). The simple fact is that the statutory requirements for exempting the interest earned on the Bonds have not been met. As with other debtor- creditor relationships, the risk that the issuer of bonds will not live up to the responsibilities undertaken when it represented the quality of its obligations must be born by the bond purchasers. One might also sympathize with the situation of the Housing Authority of Riverside County. However, it seems clear that, as between it and the Federal Government, the Housing Authority should bear responsibility for what happened. The Housing Authority issued the Bonds and selected those who were responsible for implementing their issuance and applying the proceeds. Congress clearly wanted bond issuers to be responsible for meeting the requirements for tax exemption. The Housing Authority certified that the Bonds would qualify for tax exemption. Like any other local government bond issuer, the Housing Authority was responsible for paying any amount required by section 148(f)(2), regardless of whether it intended to generate the excess described in section 148(f)(2). It has thus far chosen not to do so. Unfortunately for its bondholders, thePage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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