On October 26, 2010, Gray & Pannell acted as bond counsel to the Bulloch County School District on issuing $13,705,000 of Qualified School Construction Bonds (QSCBs). The bonds are the second series of bonds to be issued by the School District as authorized by a referendum of the voters of Bulloch County on March 17, 2009. The School District elected to designate the bonds as Direct Pay Tax Credit Bonds pursuant to Section 6431 of the Internal Revenue Code. This entitles the School District to subsidy payments equal to the lesser of the amount of interest payable on the bonds or the amount of interest which would have been payable on the bonds if the interest were determined under the Qualified Tax Credit Bond Rate as established by the U.S. Treasury. At the time of the pricing of the bonds, the yield on the bonds was less than the Qualified Tax Credit Bond Rate; therefore, the School District expects to receive subsidy payments that will fully cover all interest payable on the bonds.