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0 and validly issued and constitute valid and binding special obligations of the Issuer, payable solely from the Revenues (as defined in the Indenture). (d) The Indenture, the Loan Agreement and the Bonds are subject to bankruptcy, insolvency, moratorium, reorganization and other state and federal laws affecting the enforcement of creditors' rights and to general principles of equity. (e) By the terms of the Act, the Bonds shall not be deemed to constitute a debt, liability, or obligation of the Issuer or of the State of Florida or of any political subdivision thereof, or a pledge of the faith and credit of the Issuer or of the State of Florida or of any such political. subdivision, but shall be payable solely from the Revenues. (f) By .the terms of the Act, the Bonds, 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 State of Florida or local taxes after the interest rate on the Bonds has been converted from the Variable Rate to the Fixed Rate (each, as defined in the Indenture) or 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. (g) Assuming compliance with certain covenants described herein, interest on the Bonds is and will be excludable from the gross income of the holders thereof for federal income tax purposes under existing statutes, regulations and decisions, except, with respect to any Bond, during any period in which such Bond is held by a "substantial user" of the Project or a "related person" (as such terms are used in Section 147(a) of the Code, or any applicable predecessor statutory provisions). In rendering this opinion, we have relied upon the Tax Certificate and Agreement of even date herewith, made on behalf of the Borrower by its President, with respect to certain material facts within the knowledge of the Borrower, and upon the assumption that all information contained therein is complete and accurate. We advise you that the interest on the Bonds 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 the Bonds, (1) if certain capital expenditures are paid or incurred in excess of those permitted by Section [103(b)(6)(D) of the 1954 Code] (144(a)(4) of the Code] or (2) the outstanding face amount of tax exempt bonds allocable to any "test -period beneficiary" within the meaning of Section (103(b)(18) of the 1954 Codej [144(a)(10) of the Code] exceeds the amount permitted by such Section [103(b)(18)] [144(a)(10)]. There are certain other restrictions that must be met subsequent to the delivery of the Bonds in order for interest on the 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 the Bonds be rebated to the United States of America and other requirements C-3