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                                                                     EXHIBIT 8.1


                          [KIRKLAND & ELLIS LETTERHEAD]



                                 July 19, 2001



Dura Operating Corp.
4508 IDS Center
Minneapolis, MN 55402

                  Re:      Dura Operating Corp.
                           Registration Statement on Form S-4
                           Registration No. 333-

Ladies and Gentlemen:

     We are issuing this opinion letter in our capacity as special legal counsel
to Dura Operating Corp., a Delaware corporation (the "Issuer"), in connection
with the proposed offer by the Issuer (the "Exchange Offer") of up to
$458,500,000 in aggregate principal amount of the Issuer's Series D 9% Senior
Subordinated Notes due 2009 (the "Exchange Notes") in exchange for and in
replacement of the Issuer's outstanding Series B 9% Senior Subordinated Notes
due 2009 and the Issuer's outstanding Series C 9% Senior Subordinated Notes due
2009 (collectively, the "Old Notes"), pursuant to a Registration Statement on
Form S-4 filed with the Securities and Exchange Commission (the "Commission") as
of the date hereof, under the Securities Act of 1933, as amended (the "Act")
(such Registration Statement, as amended or supplemented, is hereinafter
referred to as the "Registration Statement").

     You have requested our opinion as to certain United States federal income
tax consequences of the Exchange Offer. In preparing our opinion, we have
reviewed and relied upon the Issuer's Registration Statement and such other
documents as we have deemed necessary.


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Dura Operating Corp.
July 19, 2001
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     On the basis of the foregoing, it is our opinion that the exchange of the
Old Notes for the Exchange Notes pursuant to the Exchange Offer will not be
treated as a taxable "exchange" for United States federal income tax purposes
because the Exchange Notes do not differ materially in kind or extent from the
Old Notes. The Exchange Notes received by a holder of Old Notes will be treated
as a continuation of the Old Notes in the hands of such holder and, as a result,
there will be no federal income tax consequences to such holder as a result of
such holder's exchange of Old Notes for Exchange Notes.

     The opinion set forth above is based upon the applicable provisions of the
Internal Revenue Code of 1986, as amended, the Treasury Regulations promulgated
or proposed thereunder, current positions of the Internal Revenue Service (the
"IRS") contained in published revenue rulings, revenue procedures and
announcements, existing judicial decisions and other applicable authorities. No
tax ruling has been sought from the IRS with respect to any of the matters
discussed herein. Unlike a ruling from the IRS, an opinion of counsel is not
binding on the IRS. Hence, no assurance can be given that the opinion stated in
this letter will not be successfully challenged by the IRS or by a court. We
express no opinion concerning any tax consequences of the Exchange Offer except
as expressly set forth above.

     We hereby consent to the filing of this opinion as Exhibit 8.1 to the
Registration Statement. In giving this consent, we do not hereby admit that we
are in the category of persons whose consent is required under Section 7 of the
Act or the rules and regulations of the Commission promulgated thereunder.



                                     Sincerely,

                                     /s/ KIRKLAND & ELLIS

                                     Kirkland & Ellis