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                                                                     Exhibit 8.2


                 [WILSON SONSINI GOODRICH & ROSATI LETTERHEAD]



                           July 12, 1996



Atari Corporation
455 south Mathilda Avenue
Sunnyvale, California 94086

Ladies and Gentlemen:

    We have acted as counsel for Atari Corporation, a Nevada corporation
("Atari") in connection with the preparation and execution of the Amended and
Restated Agreement and Plan of Merger dated as of April 8, 1996 and related
Certificate of Merger (the "Merger Agreement") among JT Storage, Inc., a
Delaware corporation ("JTS") and Atari. Pursuant to the Merger Agreement, Atari
will merge with and into JTS (the "Merger"). Unless otherwise defined,
capitalized terms referred to herein have the meanings set forth in the Merger
Agreement. All section references, unless otherwise indicated, are to the
Internal Revenue Code of 1986, as amended (the "Code").

    You have requested our opinion regarding certain United States federal
income tax consequences of the Merger. In delivering this opinion, we have
reviewed and relied upon the facts, statements, descriptions and representations
set forth in the Registration Statement on Form S-4 filed by Atari and JTS with
the Securities and Exchange Commission (which contains a joint proxy
statement/prospectus) (the "Registration Statement"), the Merger Agreement
(including Exhibits) and such other documents pertaining to the Merger as we
have deemed necessary or appropriate. We have also relied upon certificates of
officers of Atari and JTS respectively (the "Officers' Certificates") as well as
continuity of interest certificates executed and delivered by certain
shareholders of Atari (the "Continuity of Interest Certificates").

    In connection with rendering this opinion, we have also assumed (without any
independent investigation) that:

    1. Original documents (including signatures) are authentic, documents
submitted to us as copies conform to the original documents, and there has been
(or will be by the Effective Time) due execution and delivery of all documents
where due execution and delivery are prerequisites to effectiveness thereof;
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    2. Any statement made in any of the documents referred to herein, "to the
best of the knowledge" of any person or party is correct without such
qualification;

    3. All statements, descriptions and representations contained in any of the
documents referred to herein or otherwise made to us are true and correct in all
material respects and no actions have been (or will be) taken which are
inconsistent with such representations; and

    4. The Merger will be reported by Atari and JTS on their respective federal
income tax returns in a manner consistent with the opinion set forth below.

    Based on our examination of the foregoing items and subject to the
assumptions, exceptions, limitations and qualifications set forth herein, we are
of the opinion that, if the Merger is consummated in accordance with the Merger
Agreement (and without any waiver, breach or amendment of any of the provisions
thereof) and the statements set forth in the Officers' Certificates and the
Continuity of Interest Certificates are true and correct as of the date hereof,
on the Effective Date of the Registration Statement and at the Effective Time,
then:

         (a) For federal income tax purposes, the Merger will qualify as a
"reorganization" as defined in Section 368(a) of the Code.

         (b) No gain or loss will be recognized by holders of Atari capital
stock solely upon their receipt of JTS capital stock solely in exchange for
Atari capital stock in the Merger (except to the extent of cash received in lieu
of a fractional share of JTS capital stock).

         (c) The aggregate tax basis of the JTS capital stock received by Atari
stockholders in the Merger will be the same as the aggregate tax basis of Atari
capital stock surrendered in exchange therefor less the tax basis, if any,
allocated to fractional share interests.

         (d) The holding period of the JTS capital stock received in the Merger
will include the period for which the Atari capital stock surrendered in
exchange therefor was held, provided that the Atari capital stock is held as a
capital asset at the time of the Merger.

         (e) Cash payments received by holders of Atari capital stock in lieu of
a fractional share will be treated as if a fractional share of JTS capital stock
had been issued in the Merger and then redeemed by JTS. A stockholder of Atari
receiving such cash will generally recognize gain or loss upon such payment,
equal to the difference (if any) between such stockholder's basis in the
fractional share and the amount of cash received.
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         (f) A shareholder who exercises appraisal or dissenters' rights with
respect to a share of JTS capital stock and who receives payment for such stock
in cash should generally recognize capital gain or loss (if such share was held
as a capital asset at the time of the Merger) measured by the difference between
the shareholder's basis in such share and the amount of cash received, provided
that such payment is neither essentially equivalent to a dividend nor has the
effect of a distribution of a dividend (a "Dividend Equivalent Transaction"). A
sale of capital stock of JTS pursuant to an exercise of appraisal or dissenters'
rights will generally not be a Dividend Equivalent Transaction if, as a result
of such exercise, the shareholder exercising dissenters' rights and all parties
related to such Shareholder own no shares of JTS Stock (either actually or
constructively with the meaning of Section 318 of the Code) after the Merger.
If, however, a stockholder's sale for cash of JTS capital stock pursuant to an
exercise of appraisal or dissenters' rights is a Dividend Equivalent
Transaction, then such shareholder will generally recognize income for federal
income tax purposes in an amount up to the entire amount of cash so received.

         (g) Neither JTS nor Atari will recognize material amounts of gain
solely as a result of the Merger.

         (h) The discussion entitled "THE PROPOSED MERGER AND RELATED
TRANSACTIONS - Certain Federal Income Tax Considerations" in the Registration
Statement insofar as it relates to the statements of law or legal conclusions is
correct in all material respects.

    This opinion represents and is based upon our best judgment regarding the
application of federal income tax laws arising under the Code, existing judicial
decisions, administrative regulations and published rulings and procedures. Our
opinion is not binding upon the Internal Revenue Service or the courts, and
there is no assurance that the Internal Revenue Service will not successfully
assert a contrary position. Furthermore, no assurance can be given that future
legislative, judicial or administrative changes, on either a prospective or
retroactive basis, would not adversely affect the accuracy of the conclusions
stated herein. Nevertheless, we undertake no responsibility to advise you of any
new developments in the application or interpretation of the federal income tax
laws.

    This opinion addresses only the classification of the Merger as a
reorganization under Section 368(a) of the Code, and does not address any other
federal, state, local or foreign tax consequences that may result from the
Merger or any other transaction (including any transaction undertaken in
connection with the Merger). Furthermore, this opinion relates only to the
holders of JTS stock who hold such stock as a capital asset. No opinion is
expressed as to the Federal income tax treatment that may be relevant to a
particular investor in light of personal circumstances or to certain types of
investors subject to special treatment under the Federal income tax laws (for
example, life insurance companies, dealers in securities, taxpayers subject to
the alternative 
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minimum tax banks, tax-exempt organizations, non-United States persons, and
stockholders who acquired their shares of Atari stock pursuant to the exercise
of options or otherwise as compensation).

    No opinion is expressed as to any transaction other than the Merger as
described in the Merger Agreement or to any transaction whatsoever, including
the Merger, if all the transactions described in the Merger Agreement are not
consummated in accordance with the terms of such Merger Agreement and without
waiver or breach of any material provision thereof or if all of the
representations, warranties, statements and assumptions upon which we relied are
not true and accurate at all relevant times. In the event any one of the
statements, representations, warranties or assumptions upon which we have relied
to issue this opinion is incorrect, our opinion might be adversely affected and
may not be relied upon.

    This opinion has been delivered to you for the purposes of being included as
an exhibit to the Registration Statement and satisfying the requirements of
Section 6.1(f) of the Merger Agreement. It may not be relied upon for any other
purpose or by any other person or entity, and may not be made available to any
other person or entity without our prior written consent. We hereby consent to
the filing of this opinion as an exhibit to the Registration Statement and to
the use of our name under the heading "Certain Federal Income Tax Matters" in
the Registration Statement.

                             Very truly yours,


                             /s/ WILSON SONSINI GOODRICH & ROSATI
                             WILSON SONSINI GOODRICH & ROSATI
                             Professional Corporation