Exhibit 8.2
 
                 [LETTERHEAD OF MOORE, HORTON & CARLSON, P.C.]

                         FORM OF MISSOURI TAX OPINION



Board of Directors
Fulton Savings Bank, FSB
Fulton, Missouri 65251

RE:  Certain Missouri Income Tax Consequences Relating to Proposed Holding
     Company Conversion

Gentlemen:

In accordance with your request, set forth herein is the opinion of this firm
relating to certain Missouri income tax consequences of (i) the proposed
conversion of Fulton Savings Bank, FSB (the "Bank") from a federally-chartered
mutual savings bank to a federally-chartered stock savings bank (the "Converted
Bank") (the "Stock Conversion") and (ii) the concurrent acquisition of 100% of
the outstanding capital stock of the Converted Bank by a parent holding company
formed at the direction of the Board of Directors of the Bank and to be known as
Fulton Bancorp, Inc. (the "Holding Company").

You have previously received the opinion of Breyer & Aguggia regarding the
federal income tax consequences of the Stock Conversion and Holding Company
formation to the Bank, the Converted Bank, and the Holding Company and the
deposit account holders of the Bank under the Internal Revenue Code of 1986, 
as amended (the "Code").  The federal tax opinion concludes, inter alia, 
that the proposed transactions qualify as a tax-free reorganization under 
Section 368(a)(1)(F) of the Code.

The State of Missouri will, for income tax purposes, treat the proposed
transactions in an identical manner as they are treated by the Internal Revenue
Service for federal income tax purposes. Based upon the facts and circumstances
attendant to the Stock Conversion, and applicable provisions of the Internal
Revenue Code, it is our opinion that, under the laws of the State of Missouri,
no adverse Missouri tax consequences will be incurred by the parties to the
proposed transactions, including deposit account holders, as a result of the
Stock Conversion and Holding Company formation.

 
Board of Directors
Fulton Savings Bank, FSB
Page 2


No opinion is expressed on any matter other than income tax consequences
including, but not limited to, any franchise or capital stock taxes which 
might result from the implementation of the proposed transactions.

We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement (Form S-1) of the Holding Company filed under the
Securities Act of 1933, as amended, the Bank's Application for Approval of
Conversion (Form AC) filed with the Office of Thrift Supervision ("OTS"), 
and to the reference to us in the prospectus and proxy statement included 
therein. We also consent to the filing of this opinion as an exhibit to the
Holding Company Application H-(e)1-S filed on behalf of the Holding Company 
with the OTS.

This opinion is rendered only for the purposes expressed herein and is not to 
be relied upon by anyone other than you without our express written consent.



Mexico, Missouri
       , 1996