April 9, 1998



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

Ladies and Gentlemen:

Reference  is made to the  Pre-Effective  Amendment  No. 1 on Form S-6 (File No.
333-42257)  ("Amendment").  I am familiar with the establishment of the IDS Life
of New York  Account  8  ("Account")  which is a  separate  account  of IDS Life
Insurance Company of New York ("Company")  established by the Company's Board of
Directors  pursuant  to New York  Insurance  Law.  I am also  familiar  with the
above-referenced  Amendment  filed by the Company on behalf of the Account  with
the Securities and Exchange Commission.

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.   The Account is a separate  account of the  Company,  duly  established  and
     validly  existing  pursuant  to  New  York  law,  is  registered  as a unit
     investment trust under the Investment Company Act of 1940 and has the power
     and authority to issue the securities registered.

2.   The  securities,  being  variable  life  insurance  policies,  when issued,
     offered  and  sold in  accordance  with  the  prospectus  contained  in the
     Amendment  and,  in  compliance  with  local  law,  are legal  and  binding
     obligations of the Company in accordance with their 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 policies are not chargeable with liabilities arising
     out of any other business the Company may conduct.

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

Sincerely,



Mary Ellyn Minenko
Senior Counsel