October 21, 2004




IDS Life Insurance Company
70100 AXP Financial Center
Minneapolis, MN 55474

RE:      IDS Life Insurance Company
         Post-Effective Amendment No. 2 on Form S-2

Ladies and Gentlemen:

I am familiar with the establishment of IDS Life Account MGA ("Account"),  which
is a separate account of IDS Life Insurance Company  ("Company")  established by
the Company's Board of Directors  according to applicable  insurance law. I also
am  familiar  with  the  above-referenced  Registration  Statement  filed by the
Company on behalf of the Account with the Securities and Exchange Commission.

I have made such  examination  of law and examined such documents and records as
in my judgment are necessary and  appropriate to enable me to give the following
opinion:

1.   The Company is duly  incorporated,  validly  existing and in good  standing
     under applicable state law and is duly licensed or qualified to do business
     in each  jurisdiction  where it  transacts  business.  The  Company has all
     corporate  powers  required  to carry  on its  business  and to  issue  the
     contracts.

2.   The  Account is a validly  created  and  existing  separate  account of the
     Company and is duly authorized to issue the securities registered.

3.   The  contracts  issued by the Company,  when offered and sold in accordance
     with  the  prospectus  contained  in  the  Registration  Statement  and  in
     compliance  with  applicable  law,  will be legally  issued  and  represent
     binding obligations of the Company in accordance with their terms.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.

Sincerely,


By: /s/ Mary Ellyn Minenko
    -----------------------
        Mary Ellyn Minenko
        Counsel