Exhibit 8.1


                     McGuire, Woods, Battle & Boothe, L.L.P.
                                One James Center
                              901 East Cary Street
                            Richmond, Virginia 23219


                                  July 8, 1996



Heilig-Meyers Company
2235 Staples Mill Road
Richmond, Virginia 23230

MacSaver Financial Services, Inc.
2 Reads Ways, Suite 224
New Castle, Delaware 19720

                     Re: Registration Statement on Form S-3
                        $400,000,000 Aggregate Principal
                              Amount of Securities

Ladies and Gentlemen:

         We have been requested,  as your special tax counsel, to render federal
tax  advice  in  connection  with the  registration  of  $400,000,000  aggregate
principal  amount of (i) common  stock,  par value $2.00 per share (the  "Common
Stock"),  of Heilig-Meyers  Company, a Virginia  corporation  ("Heilig-Meyers"),
(ii) warrants to purchase the Common Stock of  Heilig-Meyers  (the  "Warrants"),
(iii) debt securities (the "Debt  Securities")of  MacSaver  Financial  Services,
Inc.,  a  Delaware  corporation  ("MFS"),  and (iv) the  guarantees  of the Debt
Securities (the "Guarantees" and,  collectively with the Common Stock , Warrants
and Debt Securities,  the "Securities") by  Heilig-Meyers,  under the Securities
Act of 1933, as amended (the "Act"), on Form S-3 to be filed with the Securities
and Exchange Commission (the "Commission") on the date hereof (the "Registration
Statement"), and the offering of such Securities from time to time, as set forth
in the prospectus contained in the Registration Statement (the "Prospectus") and
as to be set  forth  in one or  more  supplements  to  the  Prospectus  (each  a
"Prospectus Supplement").

         We have reviewed the statements set forth in the Registration Statement
under the  heading  "United  States  Taxation"  and hereby  advise you that such
statements,  insofar as they are or refer to  statements of United States law or
legal conclusions relating thereto, are accurate in all material respects.

         We hereby  consent to the  filing of this  opinion as an exhibit to the
Registration  Statement  and to the  reference  to us under the heading  "United
States Taxation" in the Registration  Statement.  We do not admit by giving this
consent that we are in the category of persons whose  consent is required  under
Section 7 of the Securities Act.

                                           Very truly yours,

                                           MCGUIRE WOODS BATTLE & BOOTHE, L.L.P.