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                                                                     EXHIBIT 8.1


   
                                March 19, 1998
    

   
TO ADVANTA BUSINESS SERVICES CORP., AS REGISTRANT;
ADVANTA LEASING RECEIVABLES CORP. IV, AS 
REGISTRANT;
ADVANTA LEASING RECEIVABLES CORP. V, AS
REGISTRANT;
THE CHASE MANHATTAN BANK, AS TRUSTEE:
    

   
               Re:    Advanta Equipment Receivables Asset-Backed Notes
    

Ladies and Gentlemen:

   
               We have acted as special tax counsel to Advanta Business Services
Corp., a Delaware corporation ("Advanta"), Advanta Leasing Receivables Corp. IV
("ALRC IV") and Advanta Leasing Receivables Corp. V ("ALRC V", and together
with Advanta and ALRC IV, the "Registrants") in connection with the Prospectus
filed by the Registrants.
    
   
    
   
               The term "Prospectus" means the prospectus included in the
Registration Statement. The term "Registration Statement" means (i) the
Registration Statement on Form S-1 (No. 333-38575, 333-38575-01 and
333-38575-02), including the exhibits thereto and (ii) any post-effective
amendment filed and declared effective prior to the date of issuance of the
Notes.
    
   
               We have examined the question of whether the Securities will
have the tax treatment described in the Prospectus. Our analysis is based
on the provisions of the Internal Revenue Code of 1986, as amended, and the
Treasury Regulations promulgated thereunder as in effect on the date hereof and
on existing judicial and administrative interpretations thereof. These
authorities are subject to change and to differing interpretations, which could
apply retroactively. The opinion of special tax counsel is not binding on the
courts or the Internal Revenue Service (the "IRS").
    

   
               In general, whether a transaction constitutes the issuance of
indebtedness or the sale of assets for federal income tax purposes is a question
of fact, the resolution of which is based primarily upon the economic substance
of the instruments and the transaction pursuant to which they are issued rather
than the form of the transaction or the manner in which the instruments are
labeled. The IRS and the courts have set forth various factors to be taken into
account in determining whether or not a transaction constitutes the issuance of
indebtedness or the sale of assets for federal income tax purposes, which we
have reviewed as they apply to the transactions described on the Prospectus.
    

               Based on the foregoing, and such legal and factual investigations
as we have deemed appropriate, we are of the opinion that for federal income tax
purposes:

   
               (1) The Securities, assuming they are issued in accordance with
the Prospectus, will have the federal income tax treatment described in the
Prospectus.
    

   
               (2) The information appearing under the caption "Federal Income
Tax Consequences" in the Prospectus provide a fair and accurate summary of all
material federal income tax consequences of an investment in the Securities.
    

   
               This opinion is furnished by us as counsel to the Registrants. We
hereby consent to the filing of this opinion as an Exhibit to the Registration
Statement and to the reference to Dewey Ballantine LLP in the Registration
Statement and the related prospectus under the heading "Legal Matters."
    

                                            Very truly yours,


                                            /s/ Dewey  Ballentine LLP