Exhibit 12 KIRKPATRICK & LOCKHART LLP 1800 MASSACHUSETTS AVENUE, NW 2ND FLOOR WASHINGTON, D.C. 20036-1800 January 24, 1996 Fidelity Devonshire Trust Fidelity Fixed-Income Trust 82 Devonshire Street Boston, MA 02109 Ladies and Gentlemen: Fidelity...Fidelity Fixed Income Trust • January 31st, 1996
Exhibit 12 KIRKPATRICK & LOCKHART LLP 1800 MASSACHUSETTS AVENUE, NW 2ND FLOOR WASHINGTON, D.C. 20036-1800 January 24, 1996 Fidelity Devonshire Trust Fidelity Fixed-Income Trust 82 Devonshire Street Boston, MA 02109 Ladies and Gentlemen: Fidelity Devonshire Trust ("FDT"), a Massachusetts business trust, on behalf of Spartan Long-Term Government Bond Fund ("Acquired"), a series of FDT, and Fidelity Fixed-Income Trust ("FFIT"), a Massachusetts business trust, on behalf of Spartan Government Income Fund ("Acquiring"), a series of FFIT, have requested our opinion as to certain federal income tax consequences of a transaction ("Reorganization") in which Acquiring will acquire all of the assets and assume all of the liabilities of Acquired in exchange solely for shares of beneficial interest in Acquiring ("Acquiring Shares") pursuant to an Agreement and Plan of Reorganization and Liquidation ("Agreement") to be entered into between Acquired and Acquiring on March 8, 1996. In rendering this op
Exhibit I AGREEMENT AND PLAN OF REORGANIZATION THIS AGREEMENT AND PLAN OF REORGANIZATION (the Agreement) is made as of the 8th day of March, 1996 by and among Fidelity Devonshire Trust, a Massachusetts business trust, on behalf of Spartan Long-Term...Exhibit I Agreement and Plan of Reorganization • January 31st, 1996 • Fidelity Fixed Income Trust
Exhibit I AGREEMENT AND PLAN OF REORGANIZATION THIS AGREEMENT AND PLAN OF REORGANIZATION (the Agreement) is made as of the 8th day of March, 1996 by and among Fidelity Devonshire Trust, a Massachusetts business trust, on behalf of Spartan Long-Term Government Bond Fund (Long-Term Government), a series of Fidelity Devonshire Trust, and Fidelity Fixed-Income Trust, a Massachusetts business trust, on behalf of Spartan Government Income Fund (Government Income), a series of Fidelity Fixed-Income Trust. Fidelity Devonshire Trust and Fidelity Fixed-Income Trust may be referred to herein collectively as the "Trusts" or each individually as a "Trust." Government Income and Long-Term Government may be referred to herein collectively as the "Funds" or each individually as the "Fund." This Agreement is intended to be, and is adopted as, a plan of reorganization within the meaning of Section 368(a)(1)(C) of the Internal Revenue Code of 1986, as amended (the Code). The reorganization will comprise:
