[Letterhead of Deloitte & Touche LLP]


October _____, 1998

The New York Tax-Exempt Income Fund, Inc.
6803 South Tucson Way
Englewood, Colorado 80112

Oppenheimer New York Municipal Fund
Two World Trade Center  34th floor
New York, New York  10048-0203


Dear Sirs:

We have reviewed the Agreement and Plan of  Reorganization  between The New York
Tax-Exempt  Income Fund,  Inc. (the "Fund") and  Oppenheimer  New York Municipal
Fund  ("ONYMF")  which is  attached  as  Exhibit  A to the Proxy  Statement  and
Prospectus  of the Fund  included as part of ONYMF's  Registration  Statement on
Form  N-14  filed  under  the  Securities  Act of  1933,  as  amended,  with the
Securities  and Exchange  Commission  on September  17, 1998 (the  "Agreement"),
concerning the  acquisition by ONYMF of  substantially  all of the assets of the
Fund solely for voting shares of beneficial  interest in ONYMF,  followed by the
distribution  of  ONYMF  shares  to the  shareholders  of the  Fund in  complete
liquidation of the Fund.

In  connection  with  the  rendering  of  this  opinion,  we have  reviewed  the
Agreement,  the most recent audited  financial  statements and related documents
and other  materials as we deemed  relevant to the  rendering  of this  opinion.
Based upon all of the  foregoing  and the  representations  made by the Fund and
ONYMF,  attached  hereto,  in our opinion,  the federal tax  consequences of the
transaction will be as follows:

          1. The  transactions  contemplated  by the Agreement will qualify as a
          tax-free  "reorganization"  within the meaning of Section 368(a)(1) of
          the Internal Revenue Code of 1986, as amended (the "Code").

          2.  The  Fund  and  ONYMF   will  each   qualify  as  a  "party  to  a
          reorganization" within the meaning of Section 368(b)(2) of the Code.

          3. No gain or loss will be recognized by the  shareholders of the Fund
          upon the distribution of shares of beneficial interest in ONYMF to the
          shareholders of the Fund, pursuant to Section 354 of the Code.

          4. Under Section 361(a) of the Code no gain or loss will be recognized
          by the Fund by reason of the transfer of its assets solely in exchange
          for Class A shares of ONYMF.

          5. Under  Section 1032 of the Code no gain or loss will be  recognized
          by ONYMF by reason of the  transfer  of the  Fund's  assets  solely in
          exchange for Class A shares of ONYMF.

          6. The  stockholders  of the Fund  will  have the same tax  basis  and
          holding  period for the shares of  beneficial  interest  in ONYMF that
          they  receive  as  they  had for  the  stock  of the  Fund  that  they
          previously   held,   pursuant   to   Sections   358(a)  and   1223(1),
          respectively, of the Code.

          7. The securities  transferred by the Fund to ONYMF will have the same
          tax basis and holding period in the hands of ONYMF as they had for the
          Fund,  pursuant to Sections 362(b) and 1223(1),  respectively,  of the
          Code.


Very truly yours



Deloitte & Touche LLP