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<br />5. The interest on the Bonds is excluded from gross income for federal income <br />tax purposes and is not an item of tax preference for purposes of the federal alternative <br />minimum tax imposed on individuals and corporations; it should be noted, however, that, <br />for the purpose of computing the alternative minimum tax imposed on such corporations <br />(as defined for federal income tax purposes), such interest is taken into account in <br />determining certain income and earnings. The opinions set forth in the preceding <br />sentence are subject to the condition that the City comply with all requirements of the <br />Code that must be satisfied subsequent to the issuance of the Bonds in order that <br />interest thereon be, or continue to be, excluded from gross income for federal income <br />tax purposes. The City has covenanted to comply with each such requirement. Failure <br />to comply with certain of such requirements may cause the inclusion of interest on the <br />Bonds in gross income for federal income tax purposes to be retroactive to the date of <br />issuance of the Bonds. We express no opinion regarding other federal tax consequences <br />arising with respect to the Bonds. <br /> <br />6. The interest on the Bonds is exempt from personal income taxation imposed <br />by the State of California. <br /> <br />The rights of the owners of the Bonds and the enforceability of the Bonds and the <br />Resolution may be subject to bankruptcy, insolvency, reorganization, moratorium and <br />other similar laws affecting creditors' rights heretofore or hereafter enacted and may also <br />be subject to the exercise of judicial discretion in appropriate cases. <br /> <br />Respectfully submitted, <br /> <br />A Professional Law Corporation <br /> <br />EXHIBIT A <br />Page 6 <br /> <br />11261 <br />