Exhibit 12(b)

                                                July 29, 2005



Van Kampen California Value Municipal Income Trust
1 Parkview Plaza
PO Box 5555
Oakbrook Terrace, Illinois 60181-5555

Van Kampen California Quality Municipal Trust
1 Parkview Plaza
PO Box 5555
Oakbrook Terrace, Illinois 60181-5555

Ladies and Gentlemen:

                  We have acted as special counsel to the Van Kampen California
Value Municipal Income Trust (the "Acquiring Fund"), a closed-end management
investment company organized as a Massachusetts business trust, and to the Van
Kampen California Quality Municipal Trust (the "Target Fund"), a closed-end
management investment company organized as a Massachusetts business trust, in
connection with (i) the acquisition by the Acquiring Fund of all of the assets
of the Target Fund, solely in exchange for common shares of beneficial interest
of the Acquiring Fund, par value $0.01 per share, auction preferred shares of
the Acquiring Fund, par value of $0.01 per share and with a liquidation
preference of $25,000 per share, and the assumption by the Acquiring Fund of all
of the liabilities of the Target Fund and (ii) the subsequent liquidation of the
Target Fund (collectively, the "Reorganization"), pursuant to the Agreement and
Plan of Reorganization, dated February 3, 2005, between the Acquiring Fund and
the Target Fund (the "Agreement"). You have requested our opinion regarding
whether the Reorganization will be treated for United States federal income tax
purposes as a reorganization qualifying under Section 368(a) of the Internal
Revenue Code of 1986, as amended (the "Code"). Unless otherwise defined,
capitalized terms used in this opinion have the meanings assigned to them in the
Agreement.

                  In connection with our opinion, we have reviewed originals or
copies, certified or otherwise identified to our satisfaction, of the Agreement,
the Proxy Statement/Prospectus (prepared with respect to the Reorganization),
the Statement of Additional Information (also prepared with respect to the
Reorganization) and such other documents, certificates and records as we have
deemed necessary or appropriate as a basis for the opinion set forth below. We
have assumed that the Reorganization will be consummated in accordance with the
Agreement, the Proxy Statement/Prospectus, the Statement of Additional
Information and such other documents, certificates and records.

                  For purposes of our opinion, we have assumed the legal
capacity of all natural persons, the genuineness of all signatures, the
authenticity of all documents submitted to us as originals, the conformity to
original documents of all documents submitted to us as certified, conformed or
photostatic copies and the authenticity of the originals of such latter
documents. We have assumed that such documents, certificates and records are
duly authorized, valid and enforceable.

                  In rendering our opinion, we have also relied upon statements
and representations of officers and other representatives of the Acquiring Fund
and the Target Fund and have assumed that such statements and representations
are and will continue to be correct without regard to any qualification as to
knowledge or belief.

                  Our opinion is based on the Code, Treasury regulations,
judicial authorities, published positions of the Internal Revenue Service (the
"IRS") and such other authorities as we have considered relevant, all as in
effect as of the date of this opinion and all of which are subject to change or
differing interpretations (possibly with retroactive effect). A change in the
authorities upon which our opinion is based could affect our conclusions. An
opinion of counsel is not binding on the IRS or any court. No assurance can be
given that the IRS would not assert, or that a court would not sustain, a
position contrary to this opinion.

                  Based upon and subject to the foregoing, we are of the opinion
that, for United States federal income tax purposes, the Reorganization will be
treated as a "reorganization" within the meaning of Section 368(a) of the Code.

                  Except as set forth above, we express no other opinion. This
opinion is expressed as of the date hereof, and we are under no obligation to
supplement or revise our opinion in order to reflect any changes in applicable
law (including any changes that have retroactive effect) or any information,
statement, representation or assumption relied upon in this opinion that becomes
untrue, incorrect or incomplete. This opinion is delivered to you solely for
your benefit and cannot be relied upon by anyone else without our written
consent.



                                                     Very truly yours,

                                    /s/ Skadden, Arps, Slate, Meagher & Flom LLP