August 24, 2000
AXP Utilities Income Fund, Inc.
200 AXP Financial Center
Minneapolis, MN 55474
Gentlemen:
I have examined the Articles of Incorporation and the By-Laws of AXP Utilities
Income Fund, Inc. (the Company) and all necessary certificates, permits, minute
books, documents and records of the Company, and the applicable statutes of the
State of Minnesota, and it is my opinion that the shares sold in accordance with
applicable federal and state securities laws will be legally issued, fully paid,
and nonassessable.
This opinion may be used in connection with the Post-Effective Amendment.
Sincerely,
/s/Leslie L. Ogg
Leslie L. Ogg
Attorney at Law
901 S. Marquette Ave., Suite 2810
Minneapolis, Minnesota 55402-3268