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                                                               Exhibit 99.(i)(2)

April 27, 2005
IDS Life Insurance Company
70100 AXP Financial Center
Minneapolis, MN 55474

RE:    IDS Life Insurance Company
       Post-Effective Amendment No. 5 on Form S-1
       File No. 333-114888

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,


/s/  Mary Ellyn Minenko
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     Mary Ellyn Minenko
     Assistant General Counsel