December 12, 1997



Board of Directors
IDS Life Insurance Company of New York
20 Madison Avenue Ext.
Albany, NY  12203

Dear Members of the Board:

As Counsel and  Assistant  Secretary of IDS Life  Insurance  Company of New York
("Company"),  I am familiar with the  establishment  of the IDS Life of New York
Account 8 ("Account") which is a separate account of the Company  established by
the  Company's  Board of  Directors  pursuant  to  Section  4240 of the New York
Insurance Law. I am also familiar with the Initial  Registration  Statement Form
S-6 filed by the  Company  on  behalf of the  Account  with the  Securities  and
Exchange  Commission with respect to an indefinite amount of securities entitled
Flexible Premium Survivorship Variable Life Insurance Policy ("policy").

I have made such  examination  of law and examined such documents and records as
in my judgment are necessary and appropriate to enable me to opine as follows:

 1.  IDS Life of New York Account 8 is a separate  account of the Company,  duly
     established  and  validly  existing  pursuant  to  New  York  law,  and  is
     registered as a unit investment  trust under the Investment  Company Act of
     1940.

 2.  The policy, when issued, offered and sold in accordance with the prospectus
     contained in the aforesaid Registration Statement and, upon compliance with
     local  law,  will be a legal  and  binding  obligation  of the  Company  in
     accordance with its terms.

 3.   There is no limitation as to the number of units of the Account that may
      be issued.

 4.  Assets  allocated to and held in the Account  pursuant to New York statutes
     in accordance with the Policy are not chargeable with  liabilities  arising
     out of any other business the Company may conduct.

There is no material  pending or threatened  litigation,  claims or  assessments
(including any unasserted claims or assessments) against the Account.




Please be advised you are correct in your  understanding  that I will advise and
consult  with  you  concerning   questions  of  disclosure  and  the  applicable
requirements of Statements of Financial Accounting Standards No. 5 if, and when,
in the course of  performing  legal  services  for the Account with respect to a
matter  recognized  by me to involve an unasserted  disclosure,  I have formed a
professional  conclusion  that you must  disclose or consider  disclosure of any
such possible claim or assessment in your financial statements.  You may furnish
a copy of this letter to your independent accountants.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.

Sincerely,



William A. Stoltzmann
Counsel and Assistant Secretary
IDS Life Company of New York