EXHIBIT 8


                                                              , 1997


  Board of Directors
  Premier Bankshares Corporation
  P.O. Box 1199
  Bluefield, VA  24605-1199

  Re:    Merger of Premier Bankshares Corporation with and into
         First Virginia Banks, Inc.

  Dear Sirs:

         We  have  acted  as  counsel   for   Premier   Bankshares   Corporation
  ("Premier"),  a Virginia  corporation  and registered  bank holding company in
  connection with the Agreement and plan of Reorganization,  dated as of October
  29, 1996 (the "Affiliation  Agreement"),  between First Virginia Banks,  Inc.,
  also a  registered  bank  holding  company  ("First  Virginia")  and  Premier,
  providing for the merger of Premier into First Virginia with First Virginia to
  be the surviving corporation (the "Affiliation").  Unless otherwise specified,
  all capitalized terms have the meaning assigned to them in the Proxy Statement
  of Premier dated April , 1997.

         In  connection  with this  opinion,  we have  reviewed the  Affiliation
  Agreement and such other documents which we deem appropriate.  For purposes of
  this opinion,  we have assumed (i) the authenticity of all documents submitted
  to us as  originals,  (ii) the  conformity  to the  originals of all documents
  submitted as  certified  or  photostatic  copies and the  authenticity  of the
  originals of such copies, (iii) the genuineness of signatures not witnessed by
  us, (iv) the legal capacity of natural persons, and (v) the due authorization,
  execution and delivery of all documents and the validity and binding affect of
  such  documents.  We have further  assumed that at the  Effective  Date of the
  Affiliation,  there will be no plan or  intention by Premier  shareholders  to
  sell or  otherwise  dispose of more than 20 percent  in the  aggregate  of the
  shares  of First  Virginia  common  stock  received  in the  Affiliation.  For
  purposes of this  assumption,  the sale or redemption of any shares of Premier
  common stock in  anticipation  of the  Affiliation wil be treated as a sale of
  the  number of shares of First  Virginia  common  stock  that  would have been
  received in exchange for such shares had they not been sold or redeemed.

         Our opinion of the federal and Virginia income tax  consequences of the
Affiliation is:

         1.   Premier  and  First   Virginia   would  each  be  "a  party  to  a
  reorganization"  within  the  meaning  of  Section  368(b)(2)  and  the  flush
  paragraph of Section 368(b) of the Internal Revenue Code of 1986  (hereinafter
  cited only by section).

         2. A "plan of reorganization",  as that term is used in Section 361(a),
  would exist.

         3. The  Affiliation  would  qualify  as a  "reorganization"  within the
  meaning of Section 368(a)(1)(A) and 368(a)(2)(D).

         4. No gain or loss will be recognized by Premier on (a) the transfer of
  its assets in constructive exchange for First Virginia Common Stock or (b) the
  constructive   distribution   of  First   Virginia   shares  to  the   Premier
  stockholders.

         5. The  shareholders  of Premier would  exchange their stock in Premier
  for the stock of First  Virginia  without the  recognition  of taxable gain or
  loss  by  virtue  of  Section   354(a)(1).   Such  exchange  would  cause  the
  shareholders  of Premier to have the same basis and  holding  period for their
  First  Virginia  stock  as they had for the  stock of  Premier  by  virtue  of
  Sections 358(a) and 1223(1).

         6. The disposition of fractional shares will be taxable to the affected
  stockholder pursuant to Section 302(a).

  Except as set forth above, we express no opinion as to the tax consequences to
  any party, whether Federal,  state, local or foreign, of the Affiliation or of
  any transactions  related to the Affiliation.  This opinion is being furnished
  to you and is solely for your benefit in connection with the Affiliation,  and
  may not be relied upon for any other purpose,  or quoted or relied upon by any
  other person, firm,  corporation,  or other entity for any purpose without our
  prior written consent.

         We hereby  consent to the  filing of this  opinion as an exhibit to the
  Registration Statement to be filed with the Securities and Exchange Commission
  on Form S-4 by First Virginia Banks, Inc. in connection with this transaction.
  We also  consent to the use of our name under the caption  "Legal  Matters" in
  the prospectus and proxy statement contained in the Registration Statement.

                                                Very truly yours,

                                                GENTRY, LOCKE, RAKES & MOORE


                                                Bruce C. Stockburger