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E71 certain covenants described herein, interest on the Bonds of each Issue is excludable from gross income for purposes of federal income taxation under existing statutes, regulations and decisions, except with respect to any Bond of an Issue, during the period such Bond is held by a "substantial user" of the Project refinanced by such Issue or a "related person" (as such terms are used in Section 147(a) of the Code or any applicable predecessor provisions) and that by the terms of the Act, the Bonds of each Issue, their transfer and the income therefrom, including any profit made on the sale thereof, shall at all times be free from taxation of every kind by the State of Florida or any local unit, political subdivision or other instrumentality of the State of Florida, except taxes imposed by Chapter 220, Florida Statutes on interest income or profits on debt obligations owned by corporations; no opinion is expressed as to estate or inheritance taxes, taxes on financial institutions measured by income, any alternative minimum tax imposed on corporations or any other taxes not levied or assessed directly on the Bonds, their transfer or the income therefrom. In rendering its opinions, Co -Bond Counsel have relied upon certain Tax Certificate and Agreements made on behalf of the Company by its President with respect to certain material facts within the knowledge of the Company and upon the assumption that all information contained' therein is complete and accurate. The Code provides that the interest on the Bonds of an Issue will become includable in the gross income of the holders thereof for purposes of federal income taxation, in certain cases effective from the date of issuance of such Bonds, (a) if certain capital expenditures are paid or incurred in excess of those permitted by the Code or (b) the outstanding face amount of tax exempt bonds allocable to any "test -period beneficiary" (as defined in the Code) exceeds the amount permitted by the Code. There are certain other restrictions that must be met subsequent to the delivery of any Bonds in order for interest on such Bonds to remain excludable from gross income for federal income tax purposes, including a requirement that certain earnings received from the investment of the proceeds of such Bonds be rebated to the United States of America and other requirements applicable to the investment of the proceeds of such Bonds. The Company has covenanted in the Loan Agreement to take all action necessary to comply with the foregoing requirements and restrictions. Interest on the Bonds of the Issues indicated on the cover page o this Official Statement with an asterisk, if any, will be treated as specific preference item subject to both the individual and the corporate alternative minimum tax. Co -Bond Counsel are of the opinion that interest on the Bonds of the other Issues will not be treated as a specific preference item or other specific adjustment for purposes of either the individual or corporate alternative minimwn tax. However, for purposes of calculating the corporate alternative minimum tax for taxable years beginning in 1987, 1988 and 1989, a corporation will be required to increase its alternative minimum tax taxable income by one-half of the amount by which its "adjusted net book income" exceeds its alternative minimum tax taxable income (computed without regard to this book income adjustment) and for taxable years beginning after 1989, a corporation will be required to increase its alternative minimum tax taxable income by 75% of the amount by which its "adjusted current earnings" exceeds its alternative minimum tax taxable income (computed without regard to -46-