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7. The Property leased pursuant to the Agreement constitutes personal property and when <br /> subject to use by Lessee, will not be or become fixtures under applicable law, <br /> notwithstanding the manner in which it may be attached to the realty. <br /> 8. The Lessee is a political subdivision within the meaning of Section 103 of the Internal <br /> Revenue Code of 1954, as amended, and Treasury Regulations and Rulings related <br /> thereto. That portion of rental payments made by Lessee during the Lease term identified <br /> as interest, upon receipt, will not be includable as Federal gross income under applicable <br /> statutes, regulations, court decisions and rulings existing on the date of this opinion and <br /> consequently will be exempt from present Federal income taxes. <br /> Counsel for Lessee(Firm's Name) <br /> Name: <br /> (Si ature) <br /> Its: Corporation Counsel <br />