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DoRsEY & WHITNEY <br /> Peorss$[O]:AL Lnarrxn L[ szU PA8r"nsmP <br /> $2,650,000 General Obligation Tax City of St. Anthony, Hennepin and <br /> Increment Bonds, Series 1995B Ramsey Counties, Minnesota <br /> state's exemption of interest on its own bonds or those of its political subdivisions or <br /> Indian tribes, but not of interest on the bonds of other states or their political <br /> t subdivisions or Indian tribes, unlawfully discriminates against interstate commerce <br /> or otherwise contravenes the United States Constitution. Nevertheless, we express <br /> no opinion on the likelihood that interest on the Bonds would become taxable <br /> under this Minnesota statutory provision. <br /> We have not been asked, and have not undertaken, to review the <br /> accuracy, completeness or sufficiency of any offering materials relating to the Bonds, <br /> and accordingly, we express no opinion with respect thereto. <br /> Dated: December_, 1995. <br /> Very truly yours, - <br /> 1-3 <br />