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                                                                    EXHIBIT 8.1


               [Letterhead of Orrick, Herrington & Sutcliffe LLP]

                                  June 1, 1999

Advanta Business Services Corp.
1020 Laurel Oak Road
Voorhees, New Jersey  08043

                  Re:      Advanta Leasing Receivables Corp. VIII and Advanta
                           Leasing Receivables Corp. IX Equipment
                           Receivables Asset-Backed Notes, Series 1999-1
                           Class A, Class B and Class C
                           ---------------------------------------------------

Ladies and Gentlemen:

                  We have acted as counsel for Advanta Business Services Corp.,
a Delaware corporation ("ABS"), in connection with the preparation of the
Registration Statement on Form S-1 (the "Registration Statement"), filed on June
1, 1999 with the Securities and Exchange Commission under the Securities Act of
1933, as amended (the "Act"), for the registration under the Act of Equipment
Receivables Asset-Backed Notes, Series 1999-1, Class A, Class B and Class C
(collectively, the "Notes"). Such Notes will be issued pursuant to the Master
Facility Agreement (the "Master Facility Agreement"), among ABS, as Servicer,
Advanta Leasing Receivables Corp. VIII, as an Obligor, Advanta Leasing
Receivables Corp. IX, as an Obligor, and Bankers Trust Company, as Trustee, and
the Series 1999-1 Supplement thereto.

                  We hereby confirm that the statements set forth in the
prospectus relating to the Notes (the "Prospectus") forming a part of the
Registration Statement under the headings "Prospectus Summary -- Federal Income
Tax Status" and "Federal Income Tax Consequences," which statements have been
prepared by us, to the extent that they constitute matters of law or legal
conclusions with respect thereto, are correct in all material respects, and we
hereby adopt and confirm the opinions set forth therein.

                  We hereby consent to the filing of this opinion as an exhibit
to the Registration Statement. In giving such consent, we do not admit that we
are "experts" within the meaning of


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Advanta Business Services Corp.
June 1, 1999
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the term used in the Act or the rules and regulations of the Securities and
Exchange Commission issued thereunder, with respect to any part of the
Registration Statement, including this opinion as an exhibit or otherwise.

                                    Very truly yours,

                                    /s/ Orrick, Herrington & Sutcliffe LLP

                                    ORRICK, HERRINGTON & SUTCLIFFE LLP