EXHIBIT 8

                             OPINION AND CONSENT OF

                             LIDDELL, SAPP, ZIVLEY,
                             HILL & LABOON, L.L.P.

                             REGARDING TAX MATTERS

 
                                                                       EXHIBIT 8

                               December 18, 1997

Compass Bancshares, Inc.
15 South 20th Street
Birmingham, Alabama 35233

Gentlemen:

     You have requested our opinion with respect to the disclosures relating to
the material federal income tax consequences generally applicable to the receipt
by shareholders of Fidelity Resources Company, a Texas corporation ("Fidelity"),
of shares of common stock, $2.00 par value per share ("Compass Common Stock"),
of Compass Bancshares, Inc., a Delaware corporation ("Compass"), in connection
with the proposed merger (the "Merger") of Fidelity with and into Compass Banks
of Texas, Inc. ("Compass Texas"), a Delaware corporation and wholly-owned
subsidiary of Compass, as described in the Proxy Statement /Prospectus relating
to the Merger (the "Proxy Statement/Prospectus") forming a part of the
Registration Statement on Form S-4 (the "Registration Statement") being filed
with the Securities and Exchange Commission under the Securities Act of 1933, as
amended (the "Act").

     It is our opinion that the discussions and legal conclusions set forth in
the Proxy Statement/Prospectus under the heading "Summary-Federal Income Tax
Consequences" and "The Merger-Federal Income Tax Consequences" are accurate and
complete in all material respects and constitute our opinion of the material tax
consequences to shareholders of Fidelity receiving Compass Common Stock in the
Merger.

     Our opinion is based and conditioned upon the initial and continuing
accuracy of the facts and the factual matters assumed as set forth in the Proxy
Statement/Prospectus.  Our opinion is also based upon existing provisions of the
Internal Revenue Code of 1986, as amended, regulations promulgated or proposed
thereunder and interpretations thereof by the Internal Revenue Service and the
courts, all of which are subject to change with prospective or retroactive
effect, and our opinion could be adversely affected or rendered obsolete by any
such change.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and the use of our name in the Proxy Statement/Prospectus
under the captions "Summary-Federal Income Tax Consequences", "The Merger-
Federal Income Tax Consequences" and "Legal Opinions".  In giving this consent,
we do not thereby admit that we are within the category of persons whose consent
is required under Section 7 of the Act and the rules and regulations thereunder.

                                    Very truly yours,


                                    Liddell, Sapp, Zivley, Hill & LaBoon, LLP