Attached files
Exhibit 5.2
February 5, 2010
Wells Fargo & Company,
420 Montgomery Street,
San Francisco, California 94163.
Wells Fargo Securities, LLC
550 California Street, 14th Floor
San Francisco, California 94104.
Ladies and Gentlemen:
We have acted as special tax counsel to Wells Fargo & Company, a Delaware corporation (the Company), in connection with the issuance of $5,644,000 aggregate face amount of Notes Linked to the Russell 2000 Index due February 7, 2012 as described in the Companys prospectus supplement dated January 29, 2010 to the Companys prospectus dated June 4, 2009 (the Prospectus Supplement). We hereby confirm our opinion as set forth under the heading Supplemental U.S. Income Tax Considerations in the Prospectus Supplement.
We hereby consent to the reference to us in the Prospectus Supplement under the caption Supplemental U.S. Income Tax Considerations and the filing of this opinion as an exhibit to the Prospectus Supplement. In giving such consent, we do not admit that we are within the category of persons whose consent is required under Section 7 of the Securities Act.
Very truly yours, |
/s/ Sullivan & Cromwell LLP |