STRONG MUNICIPAL FUNDS INC
485BPOS, EX-99.R, 2000-09-28
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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


                               September 27, 2000

VIA EDGAR

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

Re:     STRONG MUNICIPAL FUNDS, INC.

Ladies and Gentlemen:

We represent Strong Municipal Funds, Inc. (the "Company"), in connection with
its filing of Post-Effective Amendment No. 30 (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/  Ellen R. Drought

                                        Ellen R. Drought
MMN:ica

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