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LEGAL MATTERS Legal matters incident to the issuance of Bonds and with regard to the tax-exempt status of the interest on Bonds (see "TAX EXEMPTION") are subject to the legal opinion ofBryant, Miller and Olive, P.A., whose fees and expenses for legal services as Bond Counsel will be paid by the County from a portion of the proceeds ofBonds. The signed legal opinion, dated and premised on law in effect as of the date of original delivery of Bonds, will be delivered to the County at the time of original delivery, and the text of the opinion will be printed on Bonds. The proposed text of the legal opinion is set forth as Appendix C hereto. The actual legal opinion to be delivered may vary from that text if necessary to reflect facts and law on the date of delivery. The opinion will speak only as of its date, and subsequent distribution of the opinion by recirculation of the Official Statement or otherwise shall create no implication that Bond Counsel has reviewed or expresses any opinion concerning any of the matters referenced in the opinion subsequent to its date. Certain legal matters incident to the issuance of Bonds will be passed upon for the Countybythe County Attorney and by Nabors, Giblin & Nickerson, P.A., Disclosure Counsel. TAX EXEMPTION Federal Income Tax Matters The Internal Revenue Code of 1986, as amended (the "Code") establishes certain requirements which must be met subsequent to the issuance and delivery of the Bonds in order that interest on the Bonds be and remain excluded from gross income for purposes of federal income taxation. Non-compliance may cause interest on the Bonds to be included in federal gross income retroactive to the date of issuance of the Bonds regardless of the date on which such non-compliance occurs or is ascertained. These requirements include, but are not limited to, provisions whichprescribe yield and other limits within which the proceeds of the Bonds and the other amounts are to be invested and require that certain investment earnings on the foregoing must be rebated on a periodic basis to the Treasury Department of the United States. The County has covenanted in the Resolution to comply with such requirements in order to maintain the exclusion from federal gross income of the interest on the Bonds. In the opinion of Bond Counsel, assuming compliance with the aforementioned covenants, under existing laws, regulations, judicial decisions and rulings, interest on the Bonds is excluded fromgross income of the holders thereof for purposes of federal income taxation. Interest on the Bonds is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals or corporations; however, interest on the Bonds may be subject to the alternative minimum tax when any Bond is held by a corporation. The alternative minimum taxable income of a corporation must be increased by 75% of the 24