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E-1 XEROX TELECOPIER 496 , 212 286 1786+ ;f 2 applicable to the invest"nt of the proceeds of the Bonds. The Borrower has covenanted in the Loan Agreement to take all action necessary to comply w ith the foregoing requirements and restrictions. The Indenture provides that prior to any conversion of the interest rate borne by the Bonds from the Variable Ratti to a Fixed Rate, there must be delivered to the Trustee an opinion of Bond Counsel (as defined in the Indenture) to the effect that such conversion will not adversely affect the excludability from gross income of the interest paid on the Bonds for federal income tax purposes. Accordingly, no opinion is expressed as to the federal income taxation of interest on any Bond after the interest rate on the Bonds has been converted from the Variable Rate to a Fixed Rate. (h) (Interest on the Bonds will be treated as a specific preference item subject to both the individual and the corporate alternative minimum tax.]* (Interest on the Bonds is not included in corporate or individual alternative minimum taxable income as an enumerated item of tax preference or other specific adjustment. However, for purposes of calculating the corporate alternative minimum tax for taxable years beginning in 1987, 1980 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 +lternative 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 this current earnings adjustment).. For such purposes, "adjusted net book income" and "adjusted current earnings" would include, among other items, interest income from the Bonds.] In addition, interest on the Bonds will be includable in the applicable taxable base for the purposes of determining the environmental tax imposed by the Code on corporations for taxable years beginning after December 31,. 1986, and before January 1, 1992, and the branch profits tax imposed by the. Code on foreign corporations engaged in a trade or business in the United States for taxable years beginning after December 31, 1986. In conn;ction with the issuance of the Bonds, Piper 6 Marbury has acted as counsel to the underwriter for the Bonds and not as counsel to the issuer. Very truly yours, *This alternptive will be used in the opinions rendered with respect to the Bonds of the Issues indicated on the cover page of this Official Statement with an astaTisk, if any.