October 27, 2004


AXP Variable Portfolio-Income Series, Inc.
50606 AXP Financial Center
Minneapolis, MN 55474

Gentlemen:

I have  examined the Articles of  Incorporation  and the By-Laws of AXP Variable
Portfolio-Income  Series,  Inc. (the  Company) and all  necessary  certificates,
permits,  minute books, documents and records of the Company, and the applicable
statutes of the State of Minnesota, and it is my opinion that the shares sold in
accordance  with  applicable  federal and state  securities laws will be legally
issued, fully paid, and nonassessable.

This opinion may be used in connection with the Post-Effective Amendment.

Sincerely,



/s/ Leslie L. Ogg
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    Leslie L. Ogg
    Attorney at Law
    901 S. Marquette Ave., Suite 2810
    Minneapolis, Minnesota 55402-3268