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DORS EY & WHITNEY 'L L P <br /> • MINNEAPOLIS PILLSBURY CENTER SOUTH NEW YORK <br /> WASHINGTON,D.C. - 220 SOUTH SIXTH STREET DENVER <br /> LONDON MINNEAPOLIS, MINNESOTA 55402-1498 <br /> SEATTLE <br /> BRUSSELS TELEPHONE: (612) 340-2600 <br /> PARGO <br /> HONG KONG FAX: (612) 340-2868 <br /> DES MOINES - BILLINGS <br /> ROCHESTER MISSOULA <br /> COSTA MESA GREAT FALLS <br /> City of St. Anthony <br /> St. Anthony, Minnesota <br /> Re: $690,000 General Obligation Improvement Bonds, Series 1997A <br /> City of St. Anthony, Hennepin and Ramsey Counties, Minnesota <br /> Ladies and Gentlemen: <br /> As Bond Counsel in connection with the authorization, issuance and <br /> • sale by the City of St. Anthony, Hennepin and Ramsey Counties, Minnesota (the <br /> "City"), of its General Obligation Improvement Bonds, Series 1997A dated, as <br /> originally issued, as of April 1, 1997, in the total principal amount of $690,000 (the <br /> "Bonds"), we have examined certified copies of certain proceedings taken, and <br /> certain affidavits and certificates furnished, by the City in the authorization, sale and <br /> issuance of the Bonds, including the form of the Bonds. As to questions of fact <br /> material to our opinion we have assumed the authenticity of and relied upon the <br /> proceedings, affidavits and certificates furnished to us without undertaking to verify <br /> the same by independent investigation. From our examination of such proceedings, <br /> affidavits and certificates, and based upon laws, regulations, rulings and decisions in <br /> effect on the date hereof, it is our opinion that: <br /> 1. The Bonds are valid and binding general obligations of the City <br /> enforceable in accordance with their terms. <br /> 2. The principal of and interest on the Bonds are payable from <br /> special assessments which the City has levied or agreed to levy on the property <br /> specially benefited by the improvements financed by the issuance of the Bonds and <br /> ad valorem taxes levied on all taxable property in the City, and, to any extent not so <br /> paid, from additional ad valorem taxes required.by law to be levied on all taxable <br /> property in the City without limitation of rate or amount. <br /> • 3. Interest on the Bonds (a) is not includable in gross income for <br /> federal income tax purposes or in taxable net income of individuals, estates or trusts <br /> for Minnesota income tax purposes; (b) is includable in taxable income of <br />