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~ • <br />alternative minimum taxable income for purposes of determining the alternative minimum tax imposed on <br />corporations by section 55 of the Code and for purposes of the environmental tax imposed on corporations by section <br />59A of the Code. <br />OWNERS OF THE NOTE SHOULD BE AWARE that the ownership of tax-exempt obligations may result <br />in collateral federal income tax consequences to owners which are financial institutions, life insurance and property <br />and casualty insurance companies, certtin S corporations with Subchapter C earnings and profits, individual recipients <br />of Social Security or Railroad Retirement benefits, and taxpayers who may be deemed to have incurred or continued <br />indebtedness to purchase or carry tax-exempt obligations. In addition, certain foreign corporations doing business <br />in the United States may be subject to the "branch profits tax" on their effectively-connected earnings and profits <br />(including tax-exempt interest such as interest on the Note). <br />EXCEPT AS STATED ABOVE, we express no opinion as to any other federal, state, or local income tax <br />consequences of acquiring, carrying, owning, or disposing of the Note. . <br />Respectfully submitted, <br />Page 2 of 2 pages <br />