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operate and maintain the 1991 Project, and to own, operate and maintain the <br />System. <br />2. The Resolution has been duly adopted by the County and is a <br />valid and enforceable instrument. <br />3. The Series 1991 Bonds are valid and legally binding special <br />obligations of the County and are payable from and secured by a lien upon and <br />pledge of the Pledged Funds, as that term is defined in the Resolution. <br />4. Interest on the Series 1991 Bonds is exempt from taxation under <br />the laws of the State of Florida, except estate taxes and taxes imposed by <br />Chapter 220, Florida Statutes, on interest, income or profits on debt obligations <br />owned by corporations, banks and savings associations. <br />5. The Series 1991 Bonds are not presently "arbitrage bonds" as <br />described in Section 103(b)(2) and Section 148 of the Code and applicable <br />regulations promulgated thereunder. <br />6. Interest on the Series 1991 Bonds (including any original issue <br />discount properly allocable to the holder thereof) is excluded from gross income <br />for purposes of federal income taxation and is not an item of tax preference for <br />purposes of the federal alternative minimum tax imposed on individuals and <br />corporations under present statutes, regulations and judicial decisions; although <br />it should be noted that in the case of corporations (as defined for federal <br />income tax purposes), such interest is taken into account in determining adjusted <br />current earnings for purposes of such alternative minimum tax. <br />We express no opinion regarding other federal tax consequences <br />arising with respect to the Bonds. <br />5 <br />