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from the date of issuance of the Certificates. The opinion of <br />Special Counsel assumes compliance with these covenants. <br />Special Counsel has not undertaken to determine (or to inform <br />any person) whether any actions taken (or not taken) or events <br />occurring (or not occurring) after the date of issuance of the <br />Certificates may affect the tax status of interest on the <br />Certificates. <br /> <br /> Special Counsel is further of the opinion that interest <br />with respect to the Certificates is not a specific preference <br />item for purposes of the federal individual or corporate <br />alternative minimum taxes. However, Special Counsel observes <br />that interest with respect to the Certificates is included in <br />adjusted net book income and adjusted current earnings in <br />calculating corporate alternative minimum taxable income. <br /> <br /> Although Special Counsel has rendered an opinion that <br />interest with respect to the Certificates is excluded from <br />federal gross income, the accrual or receipt of interest on the <br />Certificates may otherwise affect an Owner's federal tax <br />liability. The nature and extent of these other tax <br />consequences will depend upon the Owner's particular tax status <br />and the Owner's other items of income or deduction. Special <br />Counsel expresses no opinion regarding any such other tax <br />consequences. <br /> <br /> LITIGATION <br /> <br /> Upon the delivery of the Certificates, the City will <br />provide its certificate that there is no litigation of any <br />nature now pending against the City or, to the knowledge of its <br />officers, threatened, seeking to restrain or enjoin the <br />execution or delivery of the Lease or Trust Agreement or the <br />issuance or sale of the Certificates or in any way contesting <br />the validity of the Lease, Trust Agreement, or the <br />Certificates or any proceedings of the City taken with respect <br />to such execution, delivery or sale, or the application of any <br />monies or security provided for the payment of the Rental <br />Payments or the use of the Certificate proceeds. <br /> <br /> There are a number of lawsuits and claims pending against <br />the City. The aggregate amount of uninsured liabilities of the <br />City which may result from such suits and claims, as determined <br />by City Attorney, will not, in the opinion of the City <br />Attorney, materially affec~ the City's finances or impair its <br />ability to pay ~he Rental Payments. <br /> <br /> 48 <br /> <br /> <br />