Exhibit 8.1




                [Letterhead of Sidley Austin Brown & Wood LLP]





                                                               April 19, 2002



DaimlerChrysler Wholesale Receivables LLC
27777 Franklin Road
Southfield, Michigan 48034

Re:      DaimlerChrysler Wholesale Receivables LLC
         Registration Statement on Form S-3
         -----------------------------------------

Ladies and Gentlemen:

     We have acted as special federal tax counsel to the CARCO Auto Loan
Master Trust (the "CARCO Trust") and the DaimlerChrysler Master Owner Trust
(the "Issuer") in connection with the filing by DaimlerChrysler Wholesale
Receivables LLC, a Delaware limited liability company (the "Registrant"), of a
Registration Statement on Form S-3 (such registration statement, together with
the exhibits and any amendments thereto as of the date hereof, the
"Registration Statement") with the Securities and Exchange Commission (the
"Commission") under the Securities Act of 1933, as amended (the "Act") for the
registration under the Act of $6,000,000,000 aggregate principal amount of
auto loan asset backed notes (the "Notes") and a collateral certificate. As
described in the Registration Statement, the collateral certificate will be
issued by the CARCO Auto Loan Master Trust to the Issuer and will serve as
collateral for the Notes. Also, as described in the Registration Statement,
the Notes will be issued from time to time in one or more series with one or
more classes or subclasses, with each series being issued by the Issuer, which
is to be formed by the Registrant pursuant to a trust agreement between the
Registrant and an owner trustee. The Notes will be issued pursuant to the
Indenture and a related Indenture Supplement.

     We have advised the Registrant with respect to certain federal income tax
consequences of the proposed issuance of the Notes. This advice is summarized
under the headings "Summary--Tax Matters" and "Tax Matters--Federal Income Tax
Consequences" in the Prospectus and "Summary of Series Terms--Tax Status" in
the Prospectus Supplement, all a part of the Registration Statement. Such
description does not purport to discuss all possible federal income tax
ramifications of the proposed issuance, but with respect to those federal
income tax





consequences that are discussed, in our opinion, the description is accurate
in all material respects. We hereby confirm and adopt the opinions expressly
set forth as our opinions under the heading "Tax Matters--Federal Income Tax
Consequences" in the Prospectus and the heading "Summary of Series Terms--Tax
Status" in the Prospectus Supplement. There can be no assurance, however, that
contrary positions will not be taken by the Internal Revenue Service or that
the law will not change.

     We hereby consent to the filing of this letter as an exhibit to the
Registration Statement and to a reference to this firm (as special federal tax
counsel to the Registrant) under the heading "Tax Matters--Federal Income Tax
Consequences" in the Prospectus forming a part of the Registration Statement,
without implying or admitting that we are "experts" within the meaning of the
Act or the rules and regulations of the Commission issued thereunder, with
respect to any part of the Registration Statement, including this exhibit.


                                             Very truly yours,

                                             /s/ SIDLEY AUSTIN BROWN & WOOD LLP



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