EXHIBIT 8.2 [LETTERHEAD OF PULLMAN & COMLEY, LLC] Reply to: Bridgeport Telephone: (203) 330-2000 September 25, 1997 People's Bank [ 850 Main Street Bridgeport, Connecticut 06604 ] J.P. Morgan Securities Inc., as Representative of the Class A Underwriters and as Class B Underwriter 60 Wall Street Standard & Poor's Corporation New York, New York 10260-0060 25 Broadway New York, New York 10004 Bankers Trust Company Moody's Investors Service, Inc. Four Albany Street 99 Church Street New York, New York 10006 New York, New York 10004 RE: PEOPLE'S BANK CREDIT CARD MASTER TRUST FLOATING RATE CLASS A ASSET BACKED CERTIFICATES, SERIES 1997-2 FLOATING RATE CLASS B ASSET BACKED CERTIFICATES, SERIES 1997-2 -------------------------------------------------------------- Gentlemen: You have requested our opinion as to certain Connecticut income tax consequences of the issuance of Floating Rate Class A Asset Backed Certificates, Series 1997-2 and Floating Rate Class B Asset Backed Certificates, Series 1997-2 (collectively, the "Certificates") pursuant to an Amended and Restated Pooling and Servicing Agreement dated as of March 18, 1997, as amended from time to time, by and between People's Bank ("People's"), as seller and servicer, and Bankers Trust Company, a New York banking corporation, as trustee acting on behalf of the holders of Certificates, as the same is supplemented by the Series 1997-2 Supplement by and between the same parties and dated as of September [ ], 1997 (collectively, the "Pooling and Servicing Agreement"). Specifically, you have asked us whether the Certificates will be treated as indebtedness and whether the People's Bank Credit Card Master Trust (the "Trust") will be disregarded for Connecticut income tax purposes. Page 2 In connection with your request, we have been furnished with copies of: (a) the Registration Statement on Form S-1 (as amended by Amendment No. 1 thereto, the "Registration Statement") relating to the Certificates; (b) the Pooling and Servicing Agreement; and (c) the opinion of Mayer, Brown & Platt (upon which we have been authorized to rely) as to certain federal income tax consequences of the issuance of the Certificates. This opinion is based on those documents. Mayer, Brown & Platt has opined that for federal income tax purposes, the Trust will be disregarded and the Certificates will be characterized as indebtedness secured by the receivables which are transferred to the Trust. We assume that opinion to be correct, and based upon that assumption, it is our opinion that the Trust will be disregarded and the Certificates will be treated as indebtedness for both the Connecticut income tax applicable to individuals, trusts and estates and the Connecticut corporation business tax. Mayer, Brown & Platt has further opined that the issuance of the Certificates will not adversely affect the federal income tax characterization of the holder of any outstanding series of asset-backed certificates or any Certificate Owner (as defined in the Pooling and Servicing Agreement), or result in the Trust being subject to federal income tax at the entity level. We assume that opinion to be correct, and based upon that assumption, it is our opinion that the issuance of the Certificates will likewise not adversely affect the Connecticut income and corporation business tax characterization of the holder of any outstanding series of asset-based certificates or any Certificate Owner, or result in the Trust being subject to Connecticut income tax at the entity level. For purposes of each of the Connecticut income and corporation business taxes, the Connecticut adjusted gross income upon which tax is payable is the taxpayer's federal adjusted gross income, subject to certain adjustments which are not relevant in this case. Consequently, the characterization properly accorded to the Trust and the Certificates for federal income tax purposes will be determinative for purposes of the Connecticut income and corporation business taxes. This opinion is for your use, and may not be relied upon by any other person without our prior written consent. Very truly yours, PULLMAN & COMLEY, LLC