Exhibit 8.2
[Sullivan & Cromwell Letterhead]








                                                              October 27, 1999




Ford Motor Credit Company
The American Road
Dearborn, MI 48121


Ladies and Gentlemen:

         As special tax counsel to Ford Motor Credit Company (the  "Company") in
connection  with  the  issuance  by  the  Company  of  $5,000,000,000  aggregate
principal  amount of its 7 3/8% Notes due October 28, 2009, we hereby confirm to
you our  opinion as set forth  under the  heading  "United  States  Taxation  of
Non-United  States Persons" in the Prospectus  Supplement dated October 21, 1999
for the Notes.

         We hereby  consent  to the  filing  with the  Securities  and  Exchange
Commission of this opinion as an exhibit to the Company's current report on Form
8-K and the  reference  to us under  the  heading  "United  States  Taxation  of
Non-United States Persons" in the Prospectus Supplement. By giving the foregoing
consent  we do not admit  that we come  within the  category  of  persons  whose
consent is required under Section 7 of the Securities Act of 1933, as amended.

                                                     Very truly yours,



                                                     /s/ Sullivan & Cromwell