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condition that the Issuer comply with all requirements of the Internal Revenue Code of 1986, as <br />amended, that must be satisfied subsequent to the issuance of the Bonds in order that interest <br />thereon be, or continue to be, excludable from gross income for federal and Minnesota income <br />tax purposes. The Issuer has covenanted to comply with all such requirements. Failure to <br />comply with certain of such requirements may cause interest on the Bonds to be included in <br />gross income for federal and Minnesota income tax purposes retroactively to the date of issuance <br />of the Bonds. We express no opinion regarding tax consequences arising with respect to the <br />Bonds other than as expressly set forth herein. <br />4.The rights of the owners of the Bonds and the enforceability of the Bonds may be <br />limited by bankruptcy, insolvency, reorganization, moratorium, and other similar laws affecting <br />creditor's rights generally and by equitable principles, whether considered at law or in equity. <br />We have not been asked and have not undertaken to review the accuracy, completeness <br />or sufficiency of the Official Statement or other offering material relating to the Bonds, and <br />accordingly we express no opinion with respect thereto. <br />This opinion is given as of the date hereof and we assume no obligation to update, <br />revise, or supplement this opinion to reflect any facts or circumstances that may hereafter <br />come to our attention or any changes in law that may hereafter occur. <br />Dated , 2007 at Minneapolis, Minnesota. <br />