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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 1992 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 1992 Bonds in gross income retroactive to the <br />date of issuance of the Series 1992 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 1992 <br />Bonds and the enforceability of the Series 1992 Bonds and of the Resolution may <br />be subject to bankruptcy, insolvency, reorganization, moratorium and other <br />similar laws affecting creditors' rights heretofore or hereafter enacted and that <br />their enforcement may be subject to the exercise of judicial discretion in <br />accordance with general principles of equity. <br />Very truly yours, <br />RHOADS & SINON <br />By: <br />Charles L. Sieck <br />E-5 <br />