Exhibit 12.3



                                         August 2, 2002



Liberty Midcap Growth Fund
Liberty-Stein Roe Funds Investment Trust
One Financial Center
Boston, Massachusetts  02111

Columbia Special Fund, Inc.
Columbia Funds
1301 S.W. Fifth Avenue
Portland, Oregon  97201


Ladies and Gentlemen:

      We have acted as counsel in connection with the Agreement and Plan of
Reorganization made as of July 31, 2002 (the "Agreement"), between and among
Columbia Special Fund, Inc., an Oregon corporation (the "Acquiring Fund"), the
Liberty-Stein Roe Funds Investment Trust, a Massachusetts business trust
("Target Trust"), on behalf of one of its series, Liberty Midcap Growth Fund
(including Classes A, B, C, and Z and Stein Roe Midcap Growth Fund, Class S)
(the "Target Fund"), and Columbia Management Group, Inc., the indirect corporate
parent to Target Fund's and Acquiring Fund's investment advisor. The Agreement
describes a proposed transaction (the "Transaction") to occur on November 4,
2002, or such other date as may be decided by the parties (the "Closing Date"),
pursuant to which Acquiring Fund will acquire substantially all of the assets of
Target Fund in exchange for shares of beneficial interest in Acquiring Fund (the
"Acquiring Fund Shares") and the assumption by Acquiring Fund of certain stated
liabilities of Target Fund, following which, Acquiring Fund Shares received by
Target Fund will be distributed by Target Fund to its shareholders in
liquidation and termination of Target Fund. Capitalized terms not defined herein
are defined in the Agreement.

      Target Fund is a series of Target Trust, which is registered under the
Investment Company Act of 1940, as amended (the "1940 Act"), as an open-end
management investment company. Shares of Target Fund are redeemable at net asset
value at each shareholder's option. Target Fund has elected to be a regulated
investment company for federal income tax purposes under Section 851 of the
Internal Revenue Code of 1986, as amended (the "Code").

      Acquiring Fund is registered under the 1940 Act as an open-end management
investment company. Shares of Acquiring Fund are redeemable at net asset value
at each shareholder's option. Acquiring Fund has elected to be a regulated
investment company for federal income tax purposes under Section 851 of the
Code.


Liberty Midcap Growth Fund                                        August 2, 2002
Columbia Special Fund, Inc.



      For purposes of this opinion, we have considered the Agreement, the
Prospectus/Proxy Statement, the Registration Statement (including the items
incorporated by reference therein), and such other items as we have deemed
necessary to render this opinion. In addition, you provided us with letters
dated as of the date hereof, representing as to certain facts, occurrences and
information upon which you have indicated that we may rely in rendering this
opinion (whether or not contained or reflected in the documents and items
referred to above) (the "Representations").

      The facts you have represented as to in paragraph 5 of the letter from
Acquiring Fund dated as of the date hereof support the conclusion that Acquiring
Fund will continue the historic business of Target Fund as an open-end
investment company that seeks to obtain capital appreciation by investing its
assets primarily in the common stocks of small- and mid-capitalization
companies. Specifically, on the relevant comparison dates (as defined in
paragraph 5 of the letter from Acquiring Fund referenced above), both Target
Fund and Acquiring Fund had invested approximately 84 percent of their assets in
companies with market capitalizations below $10 billion and approximately 40
percent of their assets in companies with market capitalizations below $5
billion. In addition, as of the comparison dates, Target Fund and Acquiring Fund
had invested similar percentages of their assets in the same industry sectors,
with each of Target Fund and Acquiring Fund investing approximately a quarter of
its assets in the consumer discretionary sector and approximately 20 percent of
its assets in the information technology sector.

      Based on the foregoing Representations and our review of the documents and
items referred to above, and conditioned on (1) the Representations being true
on the Closing Date and (2) the Transaction being consummated in accordance with
the Agreement, we are of the opinion that, subject to the final two paragraphs
hereof, for federal income tax purposes:

   (i)   The Transaction will constitute a reorganization within the meaning of
         Section 368(a) of the Code, and Acquiring Fund and Target Fund will
         each be a "party to a reorganization" within the meaning of Section
         368(b) of the Code;

   (ii)  Under Section 361 of the Code, no gain or loss will be recognized by
         Target Fund upon the transfer of Target Fund's assets to Acquiring Fund
         in exchange for Acquiring Fund Shares and the assumption by Acquiring
         Fund of the liabilities of Target Fund, or upon the distribution of
         Acquiring Fund Shares by Target Fund to its shareholders in
         liquidation;

   (iii) Under Section 354 of the Code, no gain or loss will be recognized by
         Target Fund shareholders upon the exchange of their Target Fund Shares
         for Acquiring Fund Shares;

   (iv)  Under Section 358 of the Code, the aggregate basis of Acquiring Fund
         Shares that a Target Fund shareholder receives in connection with the
         Transaction will be the same as the aggregate basis of his or her
         Target Fund Shares exchanged therefor;

   (v)   Under Section 1223(1) of the Code, a Target Fund shareholder's holding
         period for his or her Acquiring Fund Shares will be determined by
         including the period for


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Liberty Midcap Growth Fund                                        August 2, 2002
Columbia Special Fund, Inc.




         which he or she held the Target Fund Shares exchanged therefor,
         provided that he or she held such Target Fund Shares as capital assets;

   (vi)  Under Section 1032 of the Code, no gain or loss will be recognized by
         Acquiring Fund upon the receipt of the assets of Target Fund in
         exchange for Acquiring Fund Shares and the assumption by Acquiring Fund
         of the liabilities of Target Fund;

   (vii) Under Section 362(b) of the Code, the basis in the hands of Acquiring
         Fund of the assets of Target Fund transferred to Acquiring Fund in the
         Transaction will be the same as the basis of such assets in the hands
         of Target Fund immediately prior to the transfer;

  (viii) Under Section 1223(2) of the Code, the holding periods of the assets of
         Target Fund in the hands of Acquiring Fund will include the periods
         during which such assets were held by Target Fund; and

   (ix)  Acquiring Fund will succeed to and take into account the items of
         Target Fund described in Section 381(c) of the Code, subject to the
         conditions and limitations specified in Sections 381, 382, 383, 384 of
         the Code and the Regulations thereunder.

      In connection with this opinion we call your attention to Revenue Ruling
87-76, 1987-2 C.B. 84, published by the Internal Revenue Service ("IRS"). In
that ruling, the IRS held that the so-called "continuity of business enterprise"
requirement necessary to tax-free reorganization treatment was not met in the
case of an acquisition of an investment company which invested in corporate
stocks and bonds by an investment company which invested in municipal bonds.
Specifically, the IRS based its ruling on its conclusion that the business of
investing in corporate stocks and bonds is not the same line of business as
investing in municipal bonds. We believe that the IRS's conclusion in this
ruling is questionable, and that, even if the IRS's conclusion is correct, the
facts of this Transaction are distinguishable from those in the published
ruling.

      We believe that Acquiring Fund and Target Fund are both engaged in the
same line of business, investing for the benefit of their respective
stockholders primarily in the securities of small- and mid-capitalization
companies to obtain capital appreciation. After the Transaction, Acquiring Fund
will continue that business for the benefit of the stockholders of both the
Target and Acquiring Funds. While Acquiring Fund will dispose of securities
formerly held by Target Fund in order to conform with its criteria for the
selection of securities, it will apply the same criteria to its own historic
investments. All proceeds generated by all such dispositions will be reinvested
in a manner fully consistent with the shared historic investment policies of
both Funds. In these circumstances, we are of the opinion that Acquiring Fund
will have continued the historic business of Target Fund - investing primarily
in the securities of small- and mid- capitalization companies to achieve capital
appreciation - and that the continuity of business enterprise doctrine should,
as a result, be satisfied. Because Revenue Ruling 87-76 is the only published
ruling dealing specifically with the application of the "continuity of business
enterprise" requirement to a reorganization involving investment companies,
however, our opinion cannot be free from doubt.


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Liberty Midcap Growth Fund                                        August 2, 2002
Columbia Special Fund, Inc.




No ruling has been or will be obtained from the IRS as to the subject matter of
this opinion and there can be no assurance that the IRS or a court of law will
concur with the opinion set forth above.

                                    Very truly yours,

                                    /s/ Ropes & Gray

                                    Ropes & Gray


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