FOULSTON & SIEFKIN L.L.P. 
700 Fourth Financial Center 
Wichita, Kansas 67202 
(316)267-6371 
 
 
March 29, 1996 
 
AmVestors Financial Corporation 
415 S.W. Eighth Avenue 
Topeka, Kansas 66603 
 
 
    Re:  Registration Statement on Form S-3 
      AmVestors Financial Corporation 1995 Agents Stock Option Plan 
 
Dear Sirs: 
 
    We have acted as special counsel to AmVestors Financial Corporation, a
Kansas corporation (the 
"Company"), in connection with the preparation and filing with the Securities
and Exchange Commission of a 
registration statement on Form S-3 and exhibits thereto (the "Registration
Statement") covering the registration under 
the Securities Act of 1933, as amended, of 500,000 shares of the Company's
common stock, no par value (the 
"Shares"), which may be offered pursuant to the Company's 1995 Agents Stock
Option Plan. 
 
    Based upon such examination, and upon consideration of applicable federal
income tax laws, and subject 
to the additional qualifications, assumptions, and limitations hereinafter set
forth, we are of the opinion that the 
description in the Registration Statement under the caption "DESCRIPTION OF
THE PLAN--Federal Income Tax 
Consequences of Plan Participation" to the extent it involves matters of law,
is correct in all material respects. 
 
    The opinion expressed above is subject to the following additional
qualifications, assumptions, and 
limitations: 
 
    (a)  The opinion expressed herein is as of the date hereof and we assume
no obligation to update or 
supplement such opinion to reflect any facts or circumstances which may
hereafter come to our attention or changes 
in law which may hereafter occur or become effective. 
 
 
 
 
Exhibit 8.1 
 

    (b)  The opinion expressed herein is furnished to you solely for use in
connection with the Registration 
Statement. 
 
 
    We consent to the filing of this opinion as Exhibit 8.1 to the
Registration Statement and to the reference 
to us under the caption "Legal Matters" in the Registration Statement. 
 
 
                   Very truly yours, 
 
 
 
                   FOULSTON & SIEFKIN L.L.P.