FT 1900 – ‘487’ on 12/31/08 – EX-99.C4B

On:  Wednesday, 12/31/08, at 2:31pm ET   ·   Effective:  12/31/08   ·   Accession #:  1445546-8-1007   ·   File #:  333-153812

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Pre-Effective Pricing Amendment
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 487         Form S-6 to Effective Amendment                      206±   869K 
 2: EX-99       Memorandum of Changes                                  1      6K 
 4: EX-99.2A    Opinion Regarding Legality                             2±     8K 
 3: EX-99.A1    Trust Agreement                                       49±   180K 
 7: EX-99.C2    Consent of Evaluator                                   1      6K 
 5: EX-99.C4A   Opinion Regarding Federal Tax Status                   4±    17K 
 6: EX-99.C4B   Opinion Regarding New York Tax Status                  2±     9K 
 8: EX-99.C4C   Opinion Regarding U.K. Tax Status                      6±    20K 

EX-99.C4B   —   Opinion Regarding New York Tax Status

CARTER LEDYARD & MILBURN LLP                
2 WALL STREET               
NEW YORK, NY 10005                

December 31, 2008               

The Bank of New York Mellon,                                                    
as Trustee of FT 1900                                                         
101 Barclay Street                                                              
New York, New York 10286                                                        

Attention: Rosalia A. Koopman                                                   
Managing Director                                         

Re:                     FT 1900                                     

Ladies and Gentlemen:                                                           

We  are  acting as special counsel with respect to New  York          
tax  matters for the unit investment trust or trusts included  in               
the series identified as FT 1900 (each, a "Trust"), which will be               
established  under  a certain Standard Terms  and  Conditions  of               
Trust dated December 9, 2003, and a related Trust Agreement dated               
as  of  today  (collectively, the "Indenture") among First  Trust               
Portfolios  L.P.,  as  Depositor (the "Depositor"),  First  Trust               
Advisors  L.P.,  as  Evaluator, First  Trust  Advisors  L.P.,  as               
Portfolio  Supervisor, FTP Services LLC, as FTPS  Unit  Servicing               
Agent,  and  The  Bank  of  New  York  Mellon  as  Trustee   (the               
"Trustee").   Pursuant to the terms of the  Indenture,  units  of               
fractional undivided interest in the Trust (the "Units") will  be               
issued in the aggregate number set forth in the Indenture.                      

We   have  examined  and  are  familiar  with  originals  or          
certified   copies,  or  copies  otherwise  identified   to   our               
satisfaction,  of such documents as we have deemed  necessary  or               
appropriate  for  the purpose of this opinion.   In  giving  this               
opinion,  we have relied upon the two opinions, each dated  today               
and  addressed to the Trustee, of Chapman and Cutler LLP, counsel               
for  the  Depositor, with respect to the factual assumptions  and               
the  matters of law set forth therein.  We have assumed that  the               
assets  of the Trust will consist exclusively of debt securities,               
equity  securities  in entities classified  as  corporations  for               
federal income tax purposes, or a combination thereof.                          

Based upon the  foregoing,  we are of the  opinion  that the          
Trust will not constitute an association taxable as a corporation               
under  the  relevant  tax laws of the State and City of New York,               
and  accordingly  will  not be  subject  to the  New  York  State               
franchise  tax (New York  State  Consolidated  Laws  Chapter  60,               
Article  9-A) or the New York City general  corporation  tax (New               
York Administrative Code Title 11, Chapter 6, Subchapter 2).                    

We  consent  to the filing of this opinion as an exhibit  to          
the  Registration  Statement  (No.  333-153812)  filed  with  the               
Securities   and   Exchange  Commission  with  respect   to   the               
registration  of the sale of the Units and to the  references  to               
our  name  in  such  Registration Statement and  the  preliminary               
prospectus included therein.                                                    

Very truly yours, 

          CARTER LEDYARD & MILBURN LLP

Dates Referenced Herein

This ‘487’ Filing		Date		Other Filings
Filed on / Effective on:		12/31/08		None on these Dates
		12/9/03
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