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independent accountants, as set forth in their report dated January 31, 1991, which is a part of Appendix B attached hereto. APPROVAL OF LEGALITY Certain legal matters incident to the authorization, issuance, sale and delivery of the Series 1991 Bonds, and the treatment of the interest thereon for federal income tax purposes, are subject to the approval of Rhoads & Sinon, Boca Raton, Florida, Bond Counsel, whose approving opinion in substantially the form attached hereto as APPENDIX E will be printed on all of the Series 1991 Bonds. In its capacity as Bond Counsel, Rhoads & Sinon has participated in the preparation of, and has reviewed those portions of this Official Statement contained under the captions "DESCRIPTION OF THE SERIES 1991 BONDS," "SECURITY FOR THE SERIES 1991 BONDS," "APPROVAL OF LEGALITY," "TAX EXEMPTION," and the "SUMMARY OF CERTAIN PROVISIONS OF THE RESOLUTION" contained in APPENDIX C to this Official Statement and the language on the cover and in the summary of this Official Statement relating to the Series 1991 Bonds, the Resolution and the tax-exempt status of the Series 1991 Bonds. The firm has not been retained to pass upon, and will not express any opinion upon, any other information contained in this Official Statement or that may be made available to prospective purchasers of the Series 1991 Bonds. Certain legal matters will be passed upon for the County by the County Attorney, Charles P. Vitunac, Vero Beach, Florida, and for the Underwriter by its counsel, Boose Casey Ciklin Lubitz Martens McBane & O'Connell, West Palm Beach, Florida. TAX EXEMPTION Opinion of Bond Counsel In the opinion of Rhoads & Sinon, Boca Raton, Florida, Bond Counsel, assuming continuing compliance by the County with certain covenants to comply with provisions of the Internal Revenue Code of 1986, as amended (the "Code"), to preserve the exclusion of interest on the Series 1991 Bonds from gross income for federal income tax purposes, interest on the Series 1991 Bonds is excluded from gross income for purposes of federal income taxation and is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations, under existing statutes, regulations and judicial decisions; although it should be noted that in the case of corporations (as defined for federal income tax purposes), such interest is taken into account in determining adjusted current 27