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r <br />-3- , 1988 <br />subject to the condition that the Issuer comply with all <br />requirements of the Code that must be satisfied subsequent to the <br />issuance of the Bonds in order that interest thereon be (or <br />continue to be) excluded from gross income for federal income tax <br />purposes. Failure to comply with certain of such requirements <br />may cause the .inclusion of interest. on the Bonds in gross income <br />for federal income tax purposes to be retroactive to the date of <br />issuance of the Bonds. The Issuer has covenanted to comply with <br />all such requirements. We express no opinion regarding other <br />federal tax consequences arising with respect to the Bonds. <br />Yours very truly, <br /> <br />• <br />