ING VARIABLE ANNUITIES

 MYLES R. TASHMAN
 Executive Vice President,
 General Counsel and Assistant Secretary


 October 25, 2001

 Members of the Board of Directors
 Golden American Life Insurance Company
 1475 Dunwoody Drive
 West Chester, PA  19380-1478

 Gentlemen:

In my capacity as Executive  Vice  President and  Assistant  Secretary of Golden
American Life Insurance Company, a Delaware domiciled corporation ("Company"), I
have supervised the preparation of the  registration  statement for the Deferred
Combination Variable and Fixed Annuity Contract  ("Contract") to be filed by the
Company with the Securities and Exchange  Commission under the Securities Act of
1933.

I am of the following opinion:

     (1)  The Company was organized in accordance  with the laws of the State of
          Delaware and is a duly authorized  stock life insurance  company under
          the laws of Delaware and the laws of those states in which the Company
          is admitted to do business;

     (2)  The Company is authorized to issue  Contracts in those states in which
          it is admitted and upon compliance with applicable local law;

     (3)  The Contracts, when issued in accordance with the prospectus contained
          in the  aforesaid  registration  statement  and upon  compliance  with
          applicable  local law,  will be legal and binding  obligations  of the
          Company in accordance with their terms;

     (4)  The  interests  in the  Contracts  will,  when  issued and sold in the
          manner described in the registration  statement,  be legal and binding
          obligations  of the Company  and will be legally  and validly  issued,
          fully paid, and non-assessable.

In arriving at the foregoing  opinion,  I have made such  examination of law and
examined  such records and other  documents  as in my judgment are  necessary or
appropriate.

I hereby  consent to the filing of this  opinion as an exhibit to the  aforesaid
registration  statement  and to the  reference  to me under the  caption  "Legal
Matters" in the prospectus contained in said registration  statement.  In giving
this  consent I do not thereby  admit that I come within the category of persons
whose consent is required  under Section 7 of the  Securities Act of 1933 or the
Rules and Regulations of the Securities and Exchange Commission thereunder.

 Sincerely,

/s/ Myles R. Tashman
--------------------
1475 Dunwoody Drive           Tel: 610-425-3405    GoldenSelect Series
West Chester, PA  19380-1478  Fax: 610-425-3735    Issued by Golden American
                                                     Life Insurance Company