[EKW & ASSOCIATES, llp Letterhead]



March 31, 2003

Board of Directors
Community First Bank
240 South Main Street
Madisonville, KY  42431

     Re:    Kentucky Income Tax Opinion Relating to the Proposed Conversion of
            Community First Bank from a Federal Mutual Savings Bank to a Federal
            Capital Stock Savings Bank
            --------------------------------------------------------------------

Members of the Board:

You have  requested our opinion as to the  Commonwealth  of Kentucky  income tax
consequences  to be accorded a  transaction  whereby  Community  First Bank (the
"Institution"),  a federally  chartered  mutual savings bank,  will convert to a
federally  chartered stock savings bank (the "Stock Bank"),  and concurrently be
acquired by Community First Bancorp, Inc. (the "Holding Company").

You have previously  received a favorable  opinion of legal counsel stating that
the  proposed  transaction  would  result  in  no  adverse  federal  income  tax
consequences to the Institution,  Stock Bank,  Holding Company,  or the eligible
account  holders  and other  preference  categories  of the  Institution  or the
shareholders of the Holding Company under the Internal  Revenue Code of 1986, as
amended ("Code").

The  federal  tax  opinion  provides  that based upon the facts of the  proposed
transaction, the conversion of the Institution from a federally chartered mutual
savings  bank to a federally  chartered  stock  savings  bank will  constitute a
reorganization  as that term is  defined in  Section  368(a)(1)(F)  of the Code.
Furthermore,  the opinion states that the Stock Bank,  Holding Company,  and the
shareholders  of the Holding  Company will recognize no gain or loss as a result
of the acquisition of 100% of Stock Bank's stock by Holding Company.

The statement of facts and representations and declarations of the management of
the Holding Company and the Institution  included in the federal tax opinion are
incorporated herein by reference.

The  Commonwealth  of  Kentucky  will,  for  income  tax  purposes,  accord  the
transaction  the identical  treatment  which it receives for federal  income tax
purposes.  Based on the facts attendant to the proposed  transaction,  it is our
opinion that under the laws and administrative provisions of the Commonwealth of
Kentucky,   including   Kentucky  Revised  Statutes  ("KRS")   141.010(3),   KRS
141.050(1),  and Rev. Pol.  41P260,  no adverse Kentucky income tax consequences
will be incurred by the Institution,  Stock Bank, Holding Company,  the eligible
account  holders or the  shareholders  of the Holding Company as a result of the
consummation of the proposed transaction.

No opinion is expressed  with respect to any matter other than the  Commonwealth
of Kentucky income tax consequences,  including but not limited to any franchise
or capital stock taxes which might result from the  consummation of the proposed
transaction.


/s/ EKW & Associates, llp

EKW & Associates, llp
Owensboro, Kentucky