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i y 470 Pillsbury Center fi 141 < 200 South Sixth Street Minneapolis MN 55402 tina.detaS (612) 337 -9300 telephone (612) 337 - 9310 fax StekinathriMran http: / /www.kennedY- graven.com CHARTERED $650,000 General Obligation Improvement Bonds of 2000 City of Centerville Anoka County, Minnesota We have acted as bond counsel in connection with the issuance by the City of Centerville, Anoka County, Minnesota, of its General Obligation Improvement Bonds of 2000, (the `Bonds "), originally dated as of November 1, 2000, in the original aggregate principal amount of $650,000. For the purpose of rendering this opinion we have examined certified copies of certain proceedings taken by the City with respect to the authorization, sale and issuance of the Bonds, including the form of the Bonds, certain other . proceedings and documents furnished by the City, and applicable laws of the State of Minnesota From our examination of such proceedings and other documents, assuming the genuineness of the signatures thereon and the accuracy of the facts stated therein, and based upon laws, regulations, rulings and decisions in effect on the date hereof; it is our opinion that: 1. The Bonds are in due form, have been duly executed and delivered, and are valid and binding general obligations of the City, enforceable in accordance with their terms. The rights of the owners of the Bonds and the enforceability of the Bonds may be limited by bankruptcy, insolvency, reorganir moratorium, and other similar laws affecting creditor's rights generally and by equitable principles, whether considered at law or in equity. 2. The principal of and interest on the Bonds are payable from special assessments levied or to be levied on property specially benefited by local improvements and ad valorem taxes for the City's share of the cost of the improvements, but if necessary for the payment thereof additional ad valorem taxes are required by law to be levied on all taxable property in the City, which taxes are not subject to any limitation as to rate or amount. 3. Interest on the Bonds is not includable in gross income of the recipient for federal income tax purposes or in taxable net income for Minnesota income tax purposes, and is not a preference item for purposes of the computation of the federal alternative minimum tax, or the computation of the Minnesota alternative minimum tax imposed on individuals, trusts and estates, but such interest is includable in the computation of "adjusted current earnings," used in the calculation of federal alternative minimum taxable income of corporations, and is subject to Minnesota franchise taxes on corporations (including financial institutions) measured by income and the alternative minimum tax base. The opinion set forth in the preceding sentence is subject to the condition that the City comply with all requirements of the Internal Revenue Code of 1986, as amended, that must be satisfied subsequent to the issuance of the Bonds in order that interest thereon be, or continue to be, excluded from gross income for federal income tax purposes and excluded from taxable net income for Minnesota income tax purposes. We express no opinion regarding other federal or state tax consequences arising with respect to the Bonds. 3JB- 185043v1 CE155 -16