Exhibit 8.1
                                                                                

                      [LETTERHEAD OF JENKENS & GILCHRIST]


                                   
                               March 12, 1997           


    
Alliance Resources Plc
Kingsbury House
15-17 King Street
London SWIY 6QU     

    
Gentlemen:     

    
     We have acted as United States tax counsel to Alliance Resources Plc, a
United Kingdom public limited company (the "Company"), in connection with the
merger (the "Merger") of LaTex Resources, Inc. ("LaTex") with and into Alliance
Resources (Delaware), Inc. ("Newco"), a newly formed wholly owned subsidiary of
the Company and the Company's registration under the Securities Act of 1933, as
amended, of (i) 21,631,895 shares of the Company's ordinary shares of 40p each
(the "Shares"), and (ii) warrants to purchase 2,242,250 shares of the Company's
ordinary shares of 40p each (the "Warrants").     

    
     In connection with this representation, we have examined the following
documents and instruments:     

    
     (a)  the Registration Statement on Form F-4 (the "Registration Statement"),
          including the Proxy Statement/Prospectus contained therein, filed with
          the Securities Exchange Commission (the "Commission"), pertaining to
          the registration of the Shares and the Warrants;     

    
     (b)  the merger agreement (the "Merger Agreement") between LaTex, Newco and
          the Company included as Appendix B to the Proxy Statement/Prospectus.
     

    
     In connection with this opinion, we have examined and are familiar with
originals or copies, certified or otherwise identified, of such documents and
records of the Company and such statutes, regulations and other instruments as
we have deemed necessary or advisable for the purposes of this opinion.  In
rendering this opinion we have relied upon the facts and disclosures set forth
in the Registration Statement and the Merger Agreement regarding the offering
and terms of the Shares and Warrants.  We have not independently verified the
accuracy of such representations or the matters set forth in such documents or
records.  As to certain facts material to its opinion, we have assumed that all
signatures on all documents presented to use are genuine, that all documents
submitted to us as originals are accurate and complete, that all information
submitted to us is accurate and complete, and that all persons executing and
delivering originals or copies of documents examined by us are competent to
execute and deliver such documents.     

 
Alliance Resources PLC
Feburary 20, 1997
Page 10

    
     Based on the foregoing, this firm is of the opinion that the discussion in
the Registration Statement of the United States tax treatment, tax effect or tax
consequences under the caption "Material Tax Considerations" is an accurate
summary of the material United States income tax consequences related to the
Merger and the  issuance of the Shares and Warrants.  This firm's opinion is
based on the provisions of the Internal Revenue Code of 1986, as amended,
proposed regulations which have not yet taken effect and which may not be
finally adopted in their current form, and regulations, rulings and judicial
decisions now in effect, all of which are subject to change.  Any such changes
may be retroactive with respect to transactions entered into prior to the date
of such changes and could modify this firm's opinion.     

        
     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement.  Consent is also given to the reference to this firm
in the Registration Statement. In giving this consent, this firm does not
thereby admit that it comes into the category of persons whose consent is
required under Section 7 of the Securities Act or the rules and regulations of
the Commission promulgated thereunder.          

    
                                    Respectfully submitted,

                                    JENKENS & GILCHRIST,
                                    a Professional Corporation     

    
                                    By: /s/  ANDRIUS R. KONTRIMAS
                                        -------------------------
                                         Andrius R. Kontrimas
                                         Authorized Signatory