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for purposes of the computation of"alternative minimum taxable income"of corporations under <br /> Section 55 of the Code and is subject to the Minnesota franchise tax imposed upon corporations, <br /> including financial institutions, measured by taxable income and the alternative minimum tax <br /> base. The Bonds are not arbitrage bonds within the meaning of Section 148 of the Code. The <br /> Bonds are"private activity bonds"within the meaning of Section 141(a)and"qualified 501(c)(3) <br /> bonds" within the meaning of Section 145 of the Code. We express no opinion as to any other <br /> federal or state tax consequences caused by the receipt or accrual of interest on the Bonds or <br /> arising from ownership of the Bonds. <br /> 5. In connection with the issuance of the Bonds, the City has adopted a housing <br /> program which is sufficient for purposes of the Act and is consistent with the City's housing <br /> plan. <br /> 6. The Issuer has designated the Bonds as "qualified tax-exempt obligations" for <br /> purposes of Section 265(b)(3) of the Code. <br /> It should be understood that the rights of the owners of the Bonds and the enforceability <br /> of the Bonds, the Indenture and the Borrower Documents may be limited by bankruptcy, <br /> insolvency, reorganization, moratorium and other similar laws affecting creditors' rights <br /> generally and by equitable principles, whether considered at law or in equity. <br /> This opinion is given as of the date hereof and we assume no obligation to revise or <br /> supplement this opinion to reflect any facts or circumstances that may hereafter come to our <br /> attention or any changes in law or facts that may hereafter occur. <br /> We hereby consent to the references to us in the Official Statement. <br /> Dated at Minneapolis, Minnesota, , 2001. <br />