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DORSEY & WHITNEY LLP $725,000 General Obligation City of St. Anthony, Hennepin, • Improvement Bonds, Series 1998A and Ramsey Counties, Minnesota -2- additional ad valorem taxes required by law to be levied-on all taxable property in the City without limitation of rate or amount. 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 income for purposes of the federal alternative minimum tax applicable to all taxpayers or the Minnesota alternative minimum tax applicable to individuals, estates and trusts; and (d) is includable in adjusted current.earnings of corporations in determining alternative minimum taxable income for purposes of the federal alternative minimum tax imposed on corporations. 4. The City has designated the Bonds as "qualified tax-exempt obligations" within'the meaning of Section 265(b)(3) of the Internal Revenue Code of 1986, as amended (the "Code"), and, financial institutions described in Section 265(b)(5) of the • Code may treat the Bonds for purposes of Section 265(b)(2) and 291(e)(1)(B) of the Code as if they were acquired on.August 7, 1986. The opinions expressed in paragraphs 1 and 2 are subject as to enforceability to the effect of any state or federal laws relating to bankruptcy, insolvency, reorganization, moratorium or creditors' rights and the exercise of judicial discretion. The opinions set forth in paragraphs 3 and 4 are subject to the condition that the City comply with all the requirements of the Code that must be satisfied subsequent to the issuance of the Bonds in order that interest thereon be, or continue to be, excluded from gross income for federal income tax purposes;and the Bonds be and continue to be qualified tax-exempt obligations. The City has covenanted in the resolution authorizing the issuance of the Bonds to comply with these continuing requirements. Failure of the City to comply with these requirements may result in the inclusion of interest on the Bonds in federal gross income and in Minnesota taxable net income, retroactive to the date of issuance of the Bonds. Except as stated in this opinion, we express no opinion regarding federal, state or other tax consequences to owners of the Bonds.