STRONG MUNICIPAL FUNDS INC
485BPOS, EX-99.R, 2000-06-29
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                              GODFREY & KAHN, S.C.
                               ATTORNEYS AT LAW
                            780 North Water Street
                           Milwaukee, Wisconsin 53202
                    Phone (414) 273-3500 Fax (414) 273-5198


                    June 27, 2000

VIA EDGAR


Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

     Re:     STRONG MUNICIPAL FUNDS, INC.

Gentlemen:

     We represent Strong Municipal Funds, Inc. (the "Company"), in connection
with its filing of Post-Effective Amendment No. 27 (the "Post-Effective
Amendment") to the Company's Registration Statement (Registration Nos. 33-7603;
811-4770) on Form N-1A under the Securities Act of 1933 (the "Securities Act")
and the Investment Company Act of 1940.  The Post-Effective Amendment is being
filed pursuant to Rule 485(b) under the Securities Act.

     We have reviewed the Post-Effective Amendment and, in accordance with Rule
485(b)(4) under the Securities Act, hereby represent that the Post-Effective
Amendment does not contain disclosures which would render it ineligible to
become effective pursuant to Rule 485(b).

     We consent to the use of this letter in the Post-Effective Amendment.

                              Very truly yours,

                              GODFREY & KAHN, S.C.

                              /s/ Renee M. Hardt

                              Renee M. Hardt


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