PricewaterhouseCoopers LLP
                                                 333 Market Street
                                           San Francisco, CA 94105-2119


December 3, 2001


Board of Trustees
American Century Government Income Trust
4500 Main Street
Kansas City, Missouri  64111

Gentlemen:

         You have requested our opinion regarding certain Federal income tax
consequences to the Short-Term Treasury Fund (the "Fund"), a series of American
Century Government Income Trust (the "Trust"), to Treasury Fund ("Acquiring"), a
series of the Trust, and to the holders of the shares of the Fund, in connection
with the proposed transfer of substantially all of the properties of the Fund to
Acquiring in exchange solely for voting shares of Acquiring ("Acquiring
Shares"), followed by the distribution of such Acquiring Shares received by the
Fund in complete liquidation and termination of the Fund (the "Reorganization"),
all pursuant to the Agreement and Plan of Reorganization included as an exhibit
to Form N-14 filed by the Trust (the "Form N-14") with the Securities and
Exchange Commission (the "Agreement").

         For purposes of this opinion, we have examined and rely upon the
following: (1)~the Agreement; (2) the Form N-14; and (3) such other documents
and instruments as we have deemed necessary or appropriate. We assume that the
Reorganization will be carried out in accordance with the terms of the Agreement
and as described in the documents and instruments we have examined.

         This opinion is based upon the assumption by us that the Fund and
Acquiring have and will each separately qualify and be treated as regulated
investment companies under Subchapter M of the Internal Revenue Code of 1986, as
amended (the "Code") for their respective taxable years that include the closing
date of the Reorganization. If this assumption is not correct, the
Reorganization may not qualify as a tax-free reorganization and, therefore, our
opinion could be altered. For purposes of rendering this opinion, we have not
been requested to undertake, nor have we undertaken, any investigation or
inquiry as to whether this assumption is and will be correct.

         This opinion is conditioned among other things upon the Reorganization
taking place in the manner described in the Agreement and the Form N-14 to which
reference is made above.

         Based upon and subject to the foregoing and the conditions below, it is
our opinion that, for Federal income tax purposes:

         (1) The transfer to Acquiring of substantially all of the Fund's
         properties in exchange solely for Acquiring Shares, followed by the
         distribution of Acquiring Shares received by the Fund in the
         Reorganization and of any money and other property of the Fund to the
         shareholders of the Fund in complete liquidation and termination of the
         Fund, will constitute a reorganization within the meaning of Section
         368(a)(1) of the Code. The Fund and Acquiring will each be "a party to
         a reorganization" within the meaning of Section 368(b) of the Code.

         (2) No gain or loss will be recognized by the Fund upon the transfer to
         Acquiring of substantially all of the Fund's properties in exchange
         solely for Acquiring Shares or upon the distribution of the Acquiring
         Shares received by the Fund in the Reorganization to Fund shareholders
         in complete liquidation and termination of the Fund.

         (3) Acquiring will recognize no gain or loss upon receiving properties
         of the Fund in exchange for Acquiring Shares.

         (4) No gain or loss will be recognized by a shareholder of the Fund on
         the distribution to such shareholder by the Fund of Acquiring Shares
         received in the Reorganization in exchange for shares of the Fund.

         (5) The basis to Acquiring of the properties of the Fund transferred to
         Acquiring in the Reorganization will be the same as the basis of those
         properties in the hands of the Fund immediately before the exchange.

         (6) The basis of Acquiring Shares received by a shareholder of the Fund
         in the Reorganization will be the same in the aggregate as the basis of
         the Fund shares surrendered by the shareholder in exchange therefor.

         (7) A Fund shareholder's holding period for the Acquiring Shares
         received by the shareholder in the Reorganization will include the
         holding period during which the shareholder held the Fund shares
         surrendered in exchange therefor, provided that the shareholder held
         such Fund shares as a capital asset on the date of the Reorganization.

         (8) Acquiring's holding periods with respect to the Fund's properties
         that Acquiring acquires in the Reorganization will include the
         respective periods for which those properties were held by the Fund
         (except to the extent that an activity or investment of Acquiring has
         the effect of diminishing or eliminating a holding period with respect
         to an asset).

         The conclusions reached in this opinion represent and are based upon
our best judgment regarding the application of Federal income tax laws arising
under the Code, judicial decisions, administrative regulations, published
rulings and other tax authorities existing as of the date of this opinion. This
opinion is not binding upon the Internal Revenue Service or the courts and there
is no guarantee that the Internal Revenue Service will not successfully assert a
contrary position. Furthermore, no assurance can be given that future
legislative or administrative changes, on either a prospective or retroactive
basis, would not adversely affect the accuracy of the conclusions stated herein.
PricewaterhouseCoopers LLP undertakes no responsibility to advise any party or
shareholder of any new developments in the application or interpretation of the
Federal income tax laws.

         This opinion does not address any Federal tax consequences of the
transactions set forth herein, or transactions related or proximate to such
transactions, except as specifically set forth herein. This opinion does not
address any state, local, foreign, or other tax consequences that may result
from any of the transactions set forth herein, or transactions related to such
transactions. This opinion may not be relied upon by any other party to this
transaction or in any other transaction without our prior written consent.

         This opinion is based upon the representations made to us and upon the
documents, facts, and assumptions that have been included or referenced herein.
In rendering our opinion, we have relied upon such representations, documents
and facts as being true, accurate and authentic without independent verification
on our part. Our opinion may be altered if all the transactions described herein
are not consummated as described herein without waiver or breach of any material
provision thereof or if the facts and assumptions set forth herein or the
representations made to us are not true and accurate at all relevant times. In
the event any one of the facts or assumptions is incorrect, in whole or in part,
the conclusions reached in this opinion might be adversely affected.

         We express no opinion as to the tax consequences of the Reorganization
except as expressly set forth above, or as to any transaction except the
Reorganization.

                                                  Very truly yours,


                                                  /s/PricewaterhouseCoopers LLP
                                                  PricewaterhouseCoopers LLP