EXHIBIT 8.1

                               ____________, 2000


Board of Directors
Provident Bankshares Corporation
114 East Lexington Street
Baltimore, Maryland 21202

Dear Board Members:

     You have requested an opinion regarding the material federal tax
consequences of a proposed transaction involving the merger of Harbor Federal
Bancorp, Inc., a Maryland corporation ("Harbor"), with and into Provident
Bankshares Corporation, a Maryland corporation ("Provident"), (the "Merger").
The Merger will be effected pursuant to the Agreement and Plan of Merger dated
as of May 3, 2000 by and between Harbor and Provident (the "Merger Agreement").
The Merger and related transactions are described in the Merger Agreement and in
the Proxy Statement/Prospectus (the "Proxy Statement") included in Provident's
Registration Statement on Form S-4 filed with the Securities and Exchange
Commission in connection with the Merger (the "Registration Statement").  All
capitalized terms used but not defined in this opinion shall have the meanings
set forth in the Merger Agreement or the Proxy Statement.

     Under the Merger Agreement, at the Effective Time, Harbor will be merged
with and into Provident and the separate existence of Harbor will cease.
Provident will be the surviving corporation and continue its corporate existence
under the laws of Maryland.  By virtue of the Merger, automatically and without
any action on the part of the holder thereof, each share of Harbor's common
stock (the "Harbor Common Stock") issued and outstanding immediately prior to
the Effective Time shall be converted into the right to receive 1.256 shares of
the common stock of Provident (the "Provident Common Stock"), subject to the
payment of cash in lieu of fractional shares.

     Our opinion is provided solely with respect to the material federal income
tax consequences of the Merger.  This opinion is being delivered at your request
and pursuant to Section 5.1(f) of the Merger Agreement.

     In connection with the opinions expressed herein, we have examined and
relied upon originals, or copies certified or otherwise identified to our
satisfaction, of the Merger Agreement and the Proxy Statement, and of such
corporate records of the parties to the Merger as we have deemed appropriate.
We have also received and relied upon, without independent verification, certain
factual representations of Harbor concerning Harbor itself as well as the
transaction and certain factual


______________, 2000
Page 2

representations of Provident concerning the transaction and certain post-Merger
plans ("Representations"). We have assumed that such Representations are true
and that the parties to the Merger will act in accordance with the Merger
Agreement. We have assumed that all daily operations of Provident will be
conducted in a manner wholly consistent with all Representations provided by
Provident. In addition, we have made such investigations of law as we have
deemed appropriate to form a basis for the opinions expressed below.

     We will rely upon the accuracy of the Representations and the statements of
facts contained in the examined documents, particularly the Merger Agreement.
We have also assumed the authenticity of all signatures, the legal capacity of
all natural persons and the conformity to the originals of all documents
submitted to us as copies.  We have assumed that the Merger will be consummated
strictly in accordance with the terms of the Merger Agreement and that the
Merger will qualify as a merger under applicable law.

     The Merger Agreement and the Proxy Statement contain a detailed description
of the Merger. These documents as well as the Representations provided by
Provident and Harbor are incorporated in this letter as part of the statement of
the facts.

                             LIMITATIONS ON OPINION

     The opinions expressed herein are rendered only with respect to the issues
specified herein. We express no opinion with respect to any other federal, state
or local tax or other legal aspect of the transaction.  If any of the above
referenced facts or Representations are not true, correct and complete in all
material respects, our opinion could be subject to change.  In issuing our
opinion, we are relying on the provisions of the Internal Revenue Code of 1986,
as amended (the "Code") and regulations issued thereunder which are cited
herein.  All such provisions are subject to change, which change can be
retroactive in effect.  Any such change could have an effect on the validity of
our opinions.  We assume no obligation to revise or supplement this opinion if
any subsequent change were to occur.

     The opinions contained herein are not binding on the Internal Revenue
Service ("IRS") or any court.  No assurance can be given that the IRS will not
take a different view of these transactions and that view may be ultimately
sustained by a court.  It is our understanding that neither party to the Merger
intends to request a ruling from the IRS concerning the Merger.


______________, 2000
Page 3

                              FEDERAL TAX OPINION

     Based on and subject to the foregoing, the facts referenced in this
opinion, the Representations referred to in this opinion, and subject to the
limitations referenced herein, it is our opinion that for federal income tax
purposes, under the current law:

     (1)  The Merger will constitute a tax-free reorganization under Section
          368(a)(1)(A) and of the Code and Harbor and Provident will each be a
          party to the reorganization.

     (2)  No gain or loss will be recognized by Provident or Harbor as a result
          of the Merger.

     (3)  No gain or loss will be recognized by the stockholders of Harbor who
          exchange all of their Harbor Common Stock solely for Provident Common
          Stock pursuant to the Merger, except to the extent of any cash
          received in lieu of a fractional share interest in Provident Common
          Stock.

     (4)  The tax basis of the Provident Common Stock received by stockholders
          who exchange their Harbor Common Stock for Provident Common Stock
          pursuant to the Merger will be the same as the tax basis of the Harbor
          Common Stock surrendered in exchange therefor, reduced by any amount
          allocable to a fractional share interest for which cash is received
          and increased by any gain recognized on the exchange.

     (5)  The holding period of Provident Common Stock received by each
          stockholder in the Merger will include the holding period of Harbor
          Common Stock exchanged therefor, provided that such stockholder held
          such Harbor Common Stock as a capital asset on the Effective Date.

                              MULDOON, MURPHY & FAUCETTE LLP