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4. Assuming compliance by all parties with the covenants in the Loan <br /> Agreement and the Indenture, interest on the Bonds is not includable in gross income for <br /> purposes of Federal income taxation or in taxable income of individuals, estates and trusts <br /> for purposes of Minnesota income taxation under present laws regulations, rulings and <br /> decisions. Interest on the Bonds is not an item of tax preference required to be included in <br /> the computation of "alternative minimum taxable income" for purposes of the federal <br /> alternative minimum tax applicable to individuals under Section 55 ofthe Code or Minnesota <br /> alternative minimum tax applicable to individuals,trusts and estates. Interest on the Bonds <br /> is includable in "adjusted current earnings" for purposes of the computation of"alternative <br /> minimum taxable income"of corporations under Section 55 ofthe Code and is subject to the <br /> Minnesota franchise tax imposed upon corporations, including financial institutions, <br /> measured by taxable income and the alternative minimum tax base. The Bonds are not <br /> arbitrage bonds within the meaning of Section 148 of the Code. The Bonds are "private <br /> activity bonds"within the meaning of Section 141(a)and"qualified 501(c)(3)bonds"within <br /> the meaning of Section 145 of the Code. We express no opinion as to any other federal or <br /> state tax consequences caused by the receipt or accrual of interest on the Bonds or arising <br /> 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 <br /> enforceability of the Bonds, the Indenture and the Borrower Documents may be limited by <br /> bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting <br /> creditors'rights 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 /> 015477;202793/167654 jf <br />