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Ftorfda Tax Matters On the date of delivery of the Series 1993 Bonds, Bond Counsel will issue an opinion to the effect that under existing statutes, regulations and judicial decisions, the Series 1993 Bonds and the income therefrom are exempt from taxation under the laws of the State of Florida, except as to estate taxes and taxes imposed by Chapter 220, Florida Statutes, on interest, income or profits on debt obligations owned by corporations, banks and savings associations. Other Federal Income Tax Matters Interest Expense Deductions for Financial Institutions Under the Code, financial institutions are disallowed 100 percent of their interest expense deductions that are allocable, by a formula, to tax-exempt obligations acquired after August 7, 1986. An exception, which reduces the amount of the disallowance, is provided for tax-exempt obligations issued by a qualified issuer that specifically designates such obligations as "qualified tax-exempt obligations" under Section 265 of the Code. The Series 1993 Bonds have not been designated as "qualified tax-exempt obligations" Financial institutions intending to purchase, Series 1993 Bonds should consult with their professional tax advisors to determine the effect of the interest expense disallowance on their federal income tax liability. Original Issue Discount In the opinion of Bond Counsel, under existing statutes, regulations and judicial decisions, the original issue discount in the selling price of those maturities of the Series 1993 Bonds being sold in the initial public offering with original issue discount is, to the extent properly allocable to each Hold --r of such Series 1993 Bonds, excludable from gross income for federal income tax purposes of such Holder, but may not be excludable from the calculation of "adjusted current earnings" for purposes of the alternative minimum tax imposed on corporations (as defined for federal income tax purposes). The original issue discount with respect to any maturity of the Series 1993 Bonds is the excess of the stated redemption price at maturity of such Series 1993 Bonds over the initial offering price at which a substantial amount of the Series 1993 Bonds of such maturity were sold to the public, excluding underwriters and other intermediaries, in the initial public offering. Accrued original issue discount will increase a Holder's lax basis in a Series 1993 Bond and affect the determination of taxable gain from any sale or exchange of such Series 1993 Bond. Prospective purchasers of the Series 1993 Bonds being sold in the initial public offering with original issue discount should consult their tax advisors for further information concerning the manner in which the original issue discount is apportioned among successive holders and the tax consequences of purchasing, holding and selling such bonds, VERIFICATION OF MATHEMATICAL COMPUTATIONS The accuracy of the mathematical computations supporting the conclusions (i) that the principal amounts and the interest on the Escrow Securities and other funds deposited in escrow under the Escrow Agreement are adequate to provide for the payment when due of the principal, interest and redemption premium, if any, on the Refunded Bonds and (ii) that the yield on the Escrow Securities or the Series 1993 Bonds does not cause the Series 1993 Bonds to be "arbitrage bonds" under Section 148 of the Internal Revenue Code of 1986, as amended, will be verified by , independent certified public accountants, based upon schedules provided by William R. Hough & Co. 24