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                                                                     Exhibit 8.1





                                                      May 25, 2000



Advanta Business Receivables Corp.
639 Isbell Road, Suite 390
Reno, Nevada 89509

         Re:      ADVANTA BUSINESS CARD MASTER TRUST
                  ASSET BACKED NOTES

Ladies and Gentlemen:

                  We have acted as special tax counsel to Advanta Business
Receivables Corp., a Nevada corporation ("ABRC"), in connection with the filing
by ABRC, on behalf of Advanta Business Card Master Trust (the "Trust"), with the
Securities and Exchange Commission under the Securities Act of 1933, as amended
(the "Act"), of a Registration Statement on Form S-3, Registration No. 333-32874
(the "Registration Statement"), and Amendment No. 1 to the Registration
Statement, filed by ABRC under the Act, registering its Asset Backed Notes
secured by receivables in a portfolio of business revolving credit card accounts
and related assets (the "Notes"). The Notes of a particular Series will be
issued pursuant to a Master Indenture (the "Indenture") between the Trust and an
indenture trustee (the "Indenture Trustee"), substantially in the form filed as
Exhibit 4.1 to the Registration Statement, and a related Series Supplement to
the Indenture (the "Series Supplement") between the Trust and the Indenture
Trustee, substantially in the form filed as Exhibit 4.2 to the Registration
Statement. Capitalized terms used herein and not otherwise defined shall have
the meanings ascribed thereto in the form of Indenture.

                  We have examined the Registration Statement, the form of
Indenture and the form of Series Supplement. We also have examined the
originals, or duplicates or certified or conformed copies, of such records,
agreements, instruments and other documents and have made such other and further
investigations as we have deemed relevant and necessary in connection with the
opinions expressed herein. As to questions of fact material to this opinion, we
have relied upon certificates of public officials and of officers and
representatives of ABRC.

                  We have assumed that at the time of execution, authentication,
issuance and delivery of any Series of Notes, each of the following will be
true: (i) each party to the related Transaction Documents will be duly formed
and validly existing under the laws of the jurisdiction of its formation; (ii)
each party to the related Transaction Documents will have the requisite power
and authority to execute, deliver, and perform its obligations under, the
related Transaction Documents to which it is a party; (iii) each of the related
Transaction Documents will have been duly authorized, executed and delivered by
the parties thereto; (iv) the related Transaction Documents will constitute the
legal, valid and binding obligations of the parties thereto, and will be
enforceable against the parties thereto in accordance with their respective
terms; (v) no consent, approval, authorization or
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Advanta Business Receivables Corp.
May 25, 2000
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order of, registration or filing with, or notice to, any governmental authority
or court will be required for the execution, delivery and performance of the
related Transaction Documents by any party thereto or the consummation of the
transactions contemplated thereby; (vi) there will be no action, proceeding or
investigation pending or threatened before any court, governmental agency or
body or other tribunal (a) asserting the invalidity of any Transaction Document
or such Notes, (b) seeking to prevent the issuance of such Notes or the
consummation of any of the transactions contemplated by the related Transaction
Documents, or (c) which would adversely affect the performance by any party of
its obligations under, or the validity or enforceability of, any of the related
Transaction Documents; and (vii) none of the transfer of the Receivables to the
Trust, the issuance or sale of such Notes, or the execution, delivery or
performance of any related Transaction Document by any party thereto (a) will
conflict with or result in a breach of, or will constitute a default under (1)
any term or provision of any material agreement, contract, instrument or
indenture to which any party to a related Transaction Document is a party or to
which it is bound, (2) any order, judgment, writ, injunction or decree of any
court or governmental agency or body or other tribunal, or (3) any law, rule or
regulation, or (b) will result in the creation or imposition of any lien, charge
or encumbrance upon the Trust Estate, except as otherwise contemplated by the
Indenture.

                  Based upon the foregoing, and subject to the qualifications
and limitations set forth herein, we are of the opinion that the statements set
forth in the prospectus included in the Registration Statement (the
"Prospectus") under the caption "Federal Income Tax Consequences," insofar as
they purport to constitute summaries of matters of United States federal income
tax law and regulations or legal conclusions with respect thereto, constitute
accurate summaries of the matters described therein in all material respects. We
hereby confirm the opinions expressly set forth under the caption "Federal
Income Tax Consequences" in the Prospectus.

                  We are members of the Bar of the State of New York, and we do
not express any opinion herein concerning any law other than the law of the
State of New York and the Federal law of the United States.

                  We hereby consent to the filing of this opinion letter as
Exhibit 8 to the Registration Statement and the use of our name under the
captions "Legal Matters" and "Federal Income Tax Consequences" in the Prospectus
included in the Registration Statement.


                                         Very truly yours,

                                         WOLF, BLOCK, SCHORR and SOLIS-COHEN LLP