Harbor Bancorp & Subsidiaries - Page 44

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          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, the            











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