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APPENDIX I PROPOSED FORM OF LEGAL OPINION DORSEY & WHITNEY s A P.rrnxwei►Iro.wtro PRo►928.0w.t Ci0Rr04TtOf.• 2200 FIRST BANK PLACE EAST MINNEAPOLIS, MIT'NESOTA 55402 (612)340-2600 TELEX 29-0605 TELECOPIER (612)340-2666 $405,000 Liquor Store Revenue Refunding Bonds, Series 1992A City of St. Anthony, Hennepin and Ramsey Counties, Minnesota We have acted as Bond Counsel in connection with the issuance by the City of St. Anthony, Hennepin and Ramsey Counties, Minnesota (the City), of the ` obligations described above, dated originally as of October ,1, 1992, in the total principal amount of $405,000 (the Bonds). For the purpose of giving this opinion we have examined certified copies of certain proceedings taken by the City in the authorization, sale and issuance of the Bonds, including the form of the Bonds, and certain other proceedings and documents furnished by the City and others. From our examination of such proceedings and other documents, assuming the authenticity thereof, the.genuineness of the signatures thereon and the accuracy of the facts stated therein, and based upon laws, regulations, rulings and decisions in effect on the date hereof, it is our opinion that: 1. The Bonds are in due form, have been duly authorized, executed and delivered, and are valid and binding special obligations of the City enforceable in accordance with their terms, except to the extent to which enforceability thereof may be limited by the exercise of judicial discretion or by federal or state laws relating to bankruptcy, reorganization, insolvency, moratorium or creditors' rights. 2. The principal of and interest on the Bonds are payable solely and exclusively from the net revenues of the municipal liquor store of the City pledged to the payment thereof. The Bonds are a first and prior lien upon the net revenues of the municipal liquor store on a parity with the lien on said net revenues to pay the Liquor Store Revenue Bonds, Series 1987 of the City (the 1987 Bonds), except that the City is authorized under certain circumstances to issue additional revenue obligations on a parity of lien with the Bonds and the 1987 Bonds. The Bonds are not general obligations of the City and the taxing power of the City is not to be used to provide money for -the payment of principal thereof or interest thereon. 3. Interest on the Bonds (a) is not includable in gross income for federal income tax purposes or in taxable net income of individuals, estates or trusts for Minnesota income tax purposes; (b) is includable in taxable income of corporations and financial institutions for purposes of the Minnesota franchise tax; (c) is not an item of tax preference includable in alternative minimum taxable F: income for purposes of the federal alternative minimum tax applicable to all taxpayers or the Minnesota alternative minimum tax applicable to individuals, -1