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DORS EY & WHITNEY L L P <br /> $1,770,000 General Obligation Taxable City of St. Anthony, Hennepin <br /> Tax Increment Bonds, Series 1996A and Ramsey Counties, Minnesota <br /> -2- <br /> and interest, ad valorem taxes are required by law to be levied on all taxable property <br /> in the City without limitation of rate or amount. <br /> 3. Interest on the Bonds will be includable in gross income for <br /> federal and State of Minnesota income tax purposes. r <br /> The opinions expressed in paragraphs 1 and 2 are subject as to <br /> enforceability to the effect of any state or federal laws relating to bankruptcy, <br /> insolvency, reorganization, moratorium or creditors' rights and the exercise of <br /> judicial discretion. <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: July 1996. • <br /> Very truly yours, <br /> I <br /> Ji <br /> 1 <br /> 1-2 <br />