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_3_ ~ 2991 <br /> <br />The opinions set farL2t in this paragraph a are subject <br />to tho condition that the Issuer comply vS.th 811 requirements OL <br />the Code that must be satisfied subsequent to the issuance at the <br />Bonds in order that intorASt thQrecn be, ax oontinuQ to Vie, <br />excludable from gross income far federal incatne tax purposes.. The <br />Issuer has covenanted to comply with eaoh such requiromant. <br />Failure to comply with ceztain of such requirements ray cause the <br />interest on the Bonds to oec-se to be excludable fron gross income <br />for federal income tax purposes, retroactive to the date of <br />issuance of the Sonds. We express nv apinian regarding other <br />federal tax consequences arising with respect to the Bands. <br />5. The interest on the Bonds is exempt from taxation <br />i.n the State of Indiana for all pt1±•poses except the Indiana <br />financial institutions tax $nd tho Indiana inheritanr_e tax_ <br />'.7ery truly yours; <br /> <br />\scatarktl~ODC(101oylnlit~1i~/6j P: <br /> <br />C <br />