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                                                                    Exhibit 8.1




June 6, 2002


Western Plains Energy, L.L.C.
414 Main St., P.O. Box 340
Quinter, Kansas 67752

Ladies and Gentlemen:

We have acted as tax counsel to Western Plains Energy, L.L.C. ("Western Plains
Energy" or "the Company"), a Kansas limited liability company, in connection
with the Company's proposed initial public offering of capital units
("Offering"). As such, we have participated in the preparation and filing with
the Securities and Exchange Commission under the Securities Act of 1933, as
amended, of a Form SB-2 Registration Statement (SEC File No. 333-74982) (the
"Registration Statement") relating to the Offering.

You have requested our opinion as to matters of federal tax law that are
described in the Registration Statement. We are assuming that the offering will
be consummated and that the operations of the Company will be conducted in a
manner consistent with that described in the Registration Statement. We have
examined the Registration Statement and such other documents as we have deemed
necessary to render our opinion expressed below.

Based on the foregoing, all statements as to matters of law and legal
conclusions contained in the Registration Statement under the heading "Federal
Income Tax Consequences" constitute our opinion unless otherwise noted. That
section of the Registration Statement contains a general description of the
principal federal income tax consequences that are expected to arise from the
ownership and disposition of units, insofar as it relates to matters of law and
legal conclusions, which addresses all material federal income tax consequences
to prospective unit holders of the ownership and disposition of units.

Our opinion extends only to matters of law and does not extent to matters of
fact. With limited exceptions, the discussion relates only to individual
citizens and residents of the United States and has limited applicability to
corporate taxpayers, tax-exempt pensions, profit-sharing trusts or IRAs,
foreign taxpayers, estates or taxable trusts as to the transferees of capital
units. An opinion of legal counsel represents an expression of legal
counsel's professional judgment regarding the subject matter of the opinion.
It is neither a guarantee of the indicated result nor is it an undertaking to
defend the indicated result should it be challenged by the Internal Revenue

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June 6, 2002


Service. This opinion is in no way binding on the Internal Revenue Service or on
any court of law.

We consent to the filing of this opinion as an exhibit to the Registration
Statement and to the reference to our firm in the Registration Statement.

Very truly yours,

/s/ Leonard, Street and Deinard, Professional Association

LEONARD, STREET AND DEINARD
PROFESSIONAL ASSOCIATION