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EXHIBIT 3.3
(ON DAY, BERRY & HOWARD LETTER)
AUGUST 16, 2000
Nuveen Investments
333 West Wacker Drive
Chicago, Illinois 60606
RE: Nuveen Tax-Free Unit Trust, Series 1187
Connecticut Traditional Trust 309
Gentlemen:
You have requested that we act as special counsel with respect to certain
Connecticut tax aspects of Connecticut Traditional Trust 309 (the "Connecticut
Traditional Trust"), being created as part of the Nuveen Tax-Free Unit Trust,
Series 1187 (the "Fund").
The Fund is created under a Trust Indenture and Agreement dated the date hereof
between Nuveen Investments, as Depositor, and The Chase Manhattan Bank, as
Trustee. The Fund will issue units in several state trusts, one of which is the
Connecticut Traditional Trust. Each unit of the Connecticut Traditional Trust (a
"Unit") represents a fractional undivided interest in the principal and net
income of the Connecticut Traditional Trust. The Connecticut Traditional Trust
and the trust for any other state included in the Fund will each be administered
as a separate and distinct entity for all purposes, each having its own separate
assets, accounts, and certificates.
You have informed us that, upon the sale of Units of the Connecticut Traditional
Trust to investors (the "Unitholders"), the assets of the Connecticut
Traditional Trust will consist of certain obligations (the "Bonds"). Each of the
Bonds has been issued by or on behalf of the State of Connecticut, a political
subdivision thereof, or public instrumentality, state or local authority,
district, or similar public entity created under the laws of the State of
Connecticut or by or on behalf of a United States territory or possession the
interest on the obligations of which Federal law would prohibit Connecticut from
taxing if received directly by a Unitholder. In the opinion of bond counsel to
the issuer of each of the Bonds, the interest thereon is exempt from Federal
income taxation. Distributions to Unitholders of interest received by the
Connecticut Traditional Trust and of amounts received thereby upon the maturity,
redemption, sale, or other disposition of the Bonds will be made semi-annually
except in the case of Unitholders who have elected a shorter distribution
period.
You have informed us that, in the opinion of Messrs. Chapman and Cutler, for
Federal income tax purposes (i) the Connecticut Traditional Trust will not be
classified as an association, but will be governed by the provisions of
subchapter J of chapter 1 of the Internal Revenue Code of 1986, relating to
trusts; (ii) pursuant to subpart E of said subchapter J, each Unitholder will be
considered to be the owner of a portion of each asset of the Connecticut
Traditional Trust and to have a portion of each item of income of the
Connecticut Traditional Trust, in each case such portion being equal to the part
of the whole thereof that the number of Units of the Connecticut Traditional
Trust held by him bears to the total number of outstanding Units of the
Connecticut Traditional Trust; (iii) each such item of income will have the same
character in the hands of a Unitholder as in the hands of the Trustee;
(iv) gain or loss will be recognized by a Unitholder upon the redemption or sale
of his Units or upon the maturity, redemption, sale, or other disposition of a
Bond held by the Connecticut Traditional Trust; and (v) such income will be
excludable from a Unitholder's Federal gross income to the extent it consists of
interest excludable therefrom for Federal income tax purposes.
Based on the foregoing, and relying explicitly on the opinion of Messrs. Chapman
and Cutler regarding Federal income tax matters, we are of the opinion that,
under existing Connecticut law:
1.--The Connecticut Traditional Trust is not subject to any tax on or measured
by net income imposed by the State of Connecticut.
2.--Interest income from a Bond held by the Connecticut Traditional Trust is not
taxable under the Connecticut tax on the Connecticut taxable income of
individuals, trusts, and estates (the "Connecticut Income Tax"), when such
interest is received by the Connecticut Traditional Trust or distributed by it
to a Unitholder.
3.--Gains and losses recognized by a Unitholder for Federal income tax purposes
upon the maturity, redemption, sale, or other disposition by the Connecticut
Traditional Trust of a Bond held by the Connecticut Traditional Trust or upon
the redemption, sale, or other disposition of a Unit of the Connecticut
Traditional Trust held by a Unitholder are taken into account as gains or
losses, respectively, for purposes of the Connecticut Income Tax, except that,
in the case of a Unitholder holding a Unit of the Connecticut Traditional Trust
as a capital asset, such gains and losses recognized upon the maturity,
redemption, sale, or exchange of a Bond issued by or on behalf of the State of
Connecticut, any political subdivision thereof, or public instrumentality, state
or local authority, district, or similar public entity created under the laws of
the State of Connecticut (a "Connecticut Bond") held
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by the Connecticut Traditional Trust are excluded from gains and losses taken
into account for purposes of such tax and no opinion is expressed as to the
treatment for purposes of such tax of gains and losses recognized, to the extent
attributable to Connecticut Bonds, upon the redemption, sale, or other
disposition by a Unitholder of a Unit of the Connecticut Traditional Trust held
by him.
4.--The portion of any interest income or capital gain of the Connecticut
Traditional Trust that is allocable to a Unitholder that is subject to the
Connecticut corporation business tax is includable in the gross income of such
Unitholder for purposes of such tax.
5.--An interest in a Unit of the Connecticut Traditional Trust that is owned by
or attributable to a Connecticut resident at the time of his death is includable
in his gross estate for purposes of the Connecticut succession tax and the
Connecticut estate tax.
We hereby consent, without admitting that we are in the category of persons
whose consent is required, to the filing of this opinion as an exhibit to the
Registration Statement relating to the Units and to the reference to our firm as
special Connecticut tax counsel in such Registration Statement and the
Prospectus contained therein.
We understand that you may deliver a copy of this opinion to the Trustee and
hereby consent to the Trustee's relying on this opinion as though it were
addressed to the Trustee.
Very truly yours,
DAY, BERRY & HOWARD LLP
