June 13, 2000



AXP Federal Income, Inc.
200 AXP Financial Center
Minneapolis, Minnesota 55474

Gentlemen:

I have  examined  the Articles of  Incorporation  and the By-Laws of AXP Federal
Income Fund, 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
     Leslie L. Ogg
     Attorney at Law
     901 S. Marquette Ave., Suite 2810
     Minneapolis, MN  55402-3268