Form of Tax Opinion for BellSouth Telecommunications, Inc. Extendible Liquidity Securities Offering

Summary

This document is a formal tax opinion letter from special tax counsel to BellSouth Telecommunications, Inc. regarding the company's $1.8 billion offering of Extendible Liquidity Securities. The counsel confirms their opinion, as stated in the prospectus supplement, that extending the maturity of these securities is unlikely to be a taxable event for U.S. federal income tax purposes. The letter also grants consent for the use of the counsel's name in the prospectus supplement, clarifying that this does not make them an "Expert" under the Securities Act of 1933.

EX-4.K 4 g65936ex4-k.txt FORM OF OPINION TO BE DELIVERED AT CLOSING 1 Exhibit 4-k Form of Tax Opinion ###-###-#### [Closing Date] BellSouth Telecommunications, Inc 675 West Peachtree Street, N.E. Atlanta, Georgia 30375 ###-###-#### Re: BellSouth Telecommunications, Inc. Extendible Liquidity Securities Dear Sirs: We have acted as special tax counsel for BellSouth Telecommunications, Inc. (the "COMPANY") in connection with the offering of $1,800,000,000 of the Company's Extendible Liquidity Securities (the "EXLS"). We hereby confirm the opinion (the "OPINION") set forth under the caption "United States Federal Income Taxation" in the prospectus supplement dated December 7, 2000 (the "PROSPECTUS SUPPLEMENT") to the Company's prospectus dated May 12, 1999. As stated in the Prospectus Supplement, it is our opinion that it is more likely than not that an election to extend the maturity of all or any portion of the principal amount of the EXLs in accordance with the procedures described in the Prospectus Supplement will not be a taxable event for U.S. federal income tax purposes. We hereby consent to the use of our name under the caption "United States Federal Income Taxation" in the Prospectus Supplement. The issuance of such a consent does not concede that we are an "Expert" for the purposes of the Securities Act of 1933. Very truly yours,