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certificate, the Series 1993 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 1993 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. The opinions <br />expressed in this paragraph are subject to the condition that the County comply <br />with all requirements of the Code that must be satisfied subsequent to the <br />issuance of the Series 1993 Bonds in order that the interest thereon be, or <br />continue to be, excluded from gross income for federal income tax purposes, as <br />the County has covenanted to do in the Resolution and other aforementioned <br />documents. Failure to comply with certain of such requirements may cause the <br />inclusion of interest on the Series 1993 Bonds in gross income retroactive to the <br />date of issuance of the Series 1993 Bonds. <br />We express no opinion regarding other federal tax consequences arising with <br />respect to the Bonds. <br />It is to be understood that the rights of the holders of the Series 1993 <br />Bonds and the enforceability of the Series 1993 Bonds and of the Resolution may <br />be subject to bankruptcy, insolvency, reorganization, moratorium and other <br />- 5 - <br />