EXHIBIT 11

                                 October 1, 2001


[SunAmerica Letterhead]


SunAmerica Income Funds
The SunAmerica Center
733 Third Avenue
New York, New York  10017-3204

Ladies and Gentlemen:

         I have acted as counsel for SunAmerica Income Funds (the "Fund"), a
Massachusetts business trust, in connection with the proposed acquisition by
each separate investment portfolio of the Fund designated as an "Acquiring Fund"
(each, an "Acquiring Fund" and, collectively, the "Acquiring Funds") in the
Agreement and Plan of Reorganization dated September 28, 2001 (the "Agreement")
by and between the Fund and North American Funds, a Massachusetts business trust
("NAF"), of all of the assets of the corresponding investment portfolio of NAF
designated as an "Acquired Fund" (each, an "Acquired Fund" and, collectively,
the "Acquired Funds") in the Agreement, in exchange solely for shares of the
respective Acquiring Fund and such Acquiring Fund's assumption of all of the
liabilities of the Acquired Fund. Capitalized terms used and not otherwise
defined herein shall have the respective meanings ascribed hereto in the Proxy
Statement and Prosepectus (as defined below).

         This opinion is furnished in connection with the Fund's Registration
Statement on Form N-14 under the Securities Act of 1933, as amended (the
"Registration Statement"), relating to Class A, Class B, Class II and Class I
shares of beneficial interest, in the case of SunAmerica Diversified Income Fund
and SunAmerica U.S. Government Securities Fund, Class A, Class B, Class II,
Class I and Class Z shares in the case of SunAmerica Core Bond Fund and
SunAmerica High Income Fund, and to Class A, Class B and Class II shares, in the
case of SunAmerica Tax Exempt Insured Fund, par value $0.01 per share (the
"Shares"), to be issued in each Reorganization.

         As counsel for the Fund, I am familiar with the proceedings taken by it
in connection with the proposed authorization, issuance and sale of the Shares.
In addition, I have examined and am familiar with the Declaration of Trust and
the By-Laws of the Fund, in each case as amended, supplemented, and in effect on
the date hereof. I have also examined a certificate issued by the Secretary of
the Commonwealth of Massachusetts, certifying the existence of the Fund and that
it is duly authorized to exercise the powers recited in its Declaration of Trust
and to transact business in the Commonwealth of Massachusetts, and such other
documents as I have deemed relevant to the matters referred to in this opinion.

         Subject to the effectiveness of the Registration Statement and
compliance with applicable state securities laws, and based on and subject to
the foregoing examination, I am of the opinion that subsequent to the approval
of the Agreement as set forth in the proxy statement and




prospectus constituting a part of the Registration Statement (the "Proxy
Statement and Prospectus"), the Shares, upon issuance in the manner referred to
in the Registration Statement, for consideration not less than the par value
thereof, will be legally issued, fully paid and non-assessable shares of
beneficial interest of the Fund (except for certain possible liability of
shareholders described in the Proxy Statement and Prospectus under "Proposals
Nos. 2(a)-(e): Approval of the Plans--Comparison of the Funds--Additional
Information--Capital Stock").

         I am a member of the Bar of the State of Maryland. Insofar as any
opinion expressed herein involves the laws of the Commonwealth of Massachusetts,
such opinion should be understood to be based on my review of the published
statutes of such state, and, where applicable, published cases of the courts and
rules or regulations of regulatory bodies of such state. I hereby consent to the
filing of this opinion as an exhibit to the Registration Statement and to the
use of my name in the Proxy Statement and Prospectus constituting a part
thereof.


                                           Very truly yours,

                                           /s/ Robert M. Zakem

                                           Robert M. Zakem, Esq.