August 31, 1999




Conseco, Inc.
Conseco Financing Trust VII
11825 North Pennsylvania Street
Carmel, IN  46032

Ladies and Gentlemen:

         We have acted as special tax counsel for Conseco, Inc. ("Conseco"), an
Indiana corporation, and Conseco Financing Trust VII (the "Trust"), a Delaware
business trust, in connection with a Registration Statement on Form S-3 filed
with the Securities and Exchange Commission on or about June 11, 1998 (as
amended through the date hereof, the "Registration Statement") which registered,
among other things, Trust Originated Preferred Securities (the "Preferred
Securities") of the Trust (liquidation amount of $25 per Preferred Security). In
connection therewith, we have reviewed portions of the Registration Statement,
including the prospectus dated June 22, 1998 (the "Prospectus") and the
prospectus supplement dated August 26, 1999 (the "Prospectus Supplement")
included therewith.

         We have examined and relied upon the Registration Statement as filed
and amended to the date of this letter. We have also examined and relied upon:
(i) the form of subordinated indenture (the "Indenture") between Conseco and
Fleet National Bank, as trustee, dated as of November 14, 1996; (ii) the form of
Sixth Supplemental Indenture (the "Supplemental Indenture") between Conseco and
State Street Bank and Trust Company, as Trustee, dated as of August 31, 1999, to
be used in connection with the issuance of the Subordinated Deferrable Interest
Debentures of Conseco due September 30, 2029 (the "Subordinated Debentures"),
which Supplemental Indenture includes the form of the Subordinated Debentures;
(iii) the form of Amended and Restated Declaration of Trust (the "Declaration")
dated as of August 31, 1999, for the Trust, which Declaration includes the form
of the Preferred Securities; (iv) the form of Preferred Securities Guarantee
Agreement (the "Guarantee") between Conseco and State Street Bank and Trust
Company as Preferred Securities Guarantee Trustee, dated as of August 31, 1999;
and (v) certain other relevant documents used in connection with the issuance of
the Subordinated Debentures, the Preferred Securities and the Guarantee
(collectively the "Operative Documents").







Conseco, Inc.
Conseco Financing Trust VI
Page 2
August 31, 1999

         As to certain questions of fact material or relevant to the opinion
expressed herein, we have relied upon a certificate obtained from an officer of
Conseco and have assumed the accuracy of the facts certified or stated to us and
have made no independent investigation of such facts.

         Based on the foregoing and assuming that the Operative Documents are
executed and delivered substantially in the form filed as exhibits to the
Registration Statement and that the transactions contemplated to occur under the
Operative Documents in fact occur in accordance with the terms thereof, we
hereby confirm that, in all material respects, the statements set forth in the
Prospectus Supplement with respect to the Trust under the heading "Certain
United States Federal Income Tax Consequences," insofar as they constitute legal
conclusions or matters of law, fairly summarize the matters referred to therein,
based upon current law and the assumptions stated or referred to therein. There
can be no assurance that contrary positions may not be taken by the Internal
Revenue Service.

         We hereby consent to the use of our name in the above-captioned
Registration Statement and to the filing of this opinion as Exhibit 8.1 to the
Registration Statement. In giving such consent, we do not thereby admit that we
are in the category of persons whose consent is required under Section 7 of the
Securities Act of 1933. This opinion is expressed as of the date hereof, unless
otherwise expressly stated, and we disclaim any undertaking to advise you of any
subsequent changes of the facts stated or assumed herein or any subsequent
changes in applicable law.

                                               Very truly yours,


                                               /S/ LEAGRE CHANDLER & MILLARD LLP