To: RISDAL Lacey L <br />Subject: RE: Golden Gardens <br />Thanks Lacey, <br />I hope you had a good vacation. <br />The issue here is around IRS rules for the use of bond proceeds. Here is the response we received from bond counsel <br />around reimbursement of expenditures related to bonds: <br />If you have a reimbursement declaration that covers the costs, and it sounds like you do, then expenditures made from <br />city funds become "stale" and therefore unreimbursable 18 months after the later of (a) the date the expenditure was <br />made or (2) the date the project was placed in service. There is also an absolute deadline of 3 years. <br />We do have a reimbursement declaration. If the park was completed in June of 2009 then we have until December 2010 <br />to reimburse expenditures. The push point here is the 3 year absolute deadline ...so the next question is are there any <br />expenditures that originally were posted prior to December 2007? If so - we'll need to journal those out of 324. The IRS <br />can audit our expenditures and we want to make sure we're in compliance. <br />If would be helpful to have the original date of expenditure for each of those expenditures you transferred as part of the <br />$500K to Fund 324 so that is clear in our file that all expenditures fall within the window. <br />Let me know if you have questions. <br />Thanks, <br />Twyl la <br />X8417 <br />From: RISDAL Lacey L <br />Sent: Thursday, June 03, 2010 12:06 PM <br />To: MILLER Twylla J <br />Subject: RE: Golden Gardens <br />Twyl la, <br />I've been on vacation, so sorry for the delay in response. The park was completed and an opening celebration held for in <br />Jun 2009. The land options expired in April 2010. The expiration of the land options is what spurred us to review the <br />funding splits of all Golden Gardens work since we knew at that point, we didn't have to reserve any additional funds for <br />GG activity. Let me know if this helps, <br />Lacey <br />From: MILLER Twylla J <br />Sent: Wednesday, May 26, 2010 8:17 AM <br />To: RISDAL Lacey L <br />Subject: Golden Gardens <br />Hi Lacey, <br />Question in relation to Golden Gardens expenditures ...what is the date the project was placed in service (completed)? <br />