Exhibit 8.2

            [LETTERHEAD OF GRIMSLEY, WHITE & COMPANY APPEARS HERE]

                                August 21, 1997



Board of Directors
Salida Building  and Loan Association


Board Members:

You have requested our opinion as to the Colorado income tax consequences
relating to the proposed conversion of Salida Building and Loan Association (the
"Bank") from a federally chartered mutual savings bank to a federally chartered
stock savings band ("Stock Bank") and the formation of High Country Bancorp,
Inc. ("Holding Company") which will acquire all of the outstanding stock of
Stock Bank.

You have submitted to us a copy of the federal income tax opinion ("Federal
Opinion") relating to the federal income tax consequences of the proposed
transactions prepared by your counsel. Housley Kantarian & Bronstein, P.C.,
Washington, D.C.

Our opinion regarding the Colorado income tax consequences of the proposed
transaction is based on the same facts and conditions contained in the Federal
Opinion dated August 21, 1997.  It is also based on existing Colorado tax law
which is subject to change.  We have not reviewed the legal documents necessary
to effectuate the steps to be undertaken, and we assume that all steps will be
properly effectuated under state and federal law and will be consistent with the
legal documentation.

In our opinion, the Colorado income tax consequences of the proposed transaction
are the same as the federal income tax consequences of the proposed transaction
identified in the Federal Opinion.

The State of Colorado has adopted federal taxable income, as currently amended,
as the starting point for computing Colorado taxable income.  Income tax terms
are defined in relation to the Internal Revenue Code of 1986 as amended.
Taxpayers are required to use the same taxable year and accounting methods as
are used in computing federal taxable income (Colorado Revised Statutes L.1992,
c330, Section 9, eff. 4-16-92)

Several specific modifications to federal taxable income are enumerated in the
Colorado Statutes in determining taxable income for Colorado purposes, however,
there are no specific modifications which apply to the proposed transaction.

 
Board of Directors
Salida Building and Loan Association
August  21, 1997
Page 2



Our opinion as expressed above is rendered only with respect to the Colorado
income tax consequences of the specific matters discussed herein, and we express
no opinion with respect to any other Colorado tax matter or any other federal,
state, local or foreign tax matter relating to the proposed transaction.  Our
opinion is based on the facts and conditions as stated herein, whether directly
or by reference to the Federal

Opinion.  If any of the foregoing is not entirely complete or accurate, it is
imperative that we be informed immediately, as the inaccuracy or incompleteness
could have a material effect on our conclusions.  In rendering our opinion, we
are relying upon the relevant provisions of the Internal Revenue Code of 1986,
as amended, and Colorado Statutes, as amended, the regulations and rules
thereunder and judicial and administrative interpretations thereof, which are
subject to change or modification by subsequent legislative, regulatory,
administrative, or judicial decisions.  Any such changes could have an effect on
the validity of our opinion.  We undertake no responsibility to update or
supplement our opinion.  Our opinion is not binding on the Internal Revenue
Service or the Colorado Department of Revenue, nor can any assurance be given
that any of the foregoing parties will not take a contrary position or that our
opinion will be upheld if challenged by such parties.



                                        Very truly yours

                                        /s/ Grimsley, White & Company