Exhibit 6

                                                   December 15, 1995

The Prudential Insurance Company
  Of America
Prudential Plaza
Newark, New Jersey  07102-3277

Gentlemen:

This opinion is furnished in connection with the registration by The Prudential
Insurance Company of America of Prudential Survivorship Preferred Variable
Appreciable Life Insurance Contract ("Contract") under the Securities Act of
1933. The prospectus included in the Pre-Effective Amendment No. 1 to
Registration No. 33-61079 on Form S-6 describes the Contract. I have reviewed
the Contract and I have participated in the preparation and review of the
Registration Statement and Exhibits thereto. In my opinion:

1.   The illustrations of cash surrender values and death benefits included in
     the section of the prospectus entitled "Illustrations of Cash Surrender
     Values, Death Benefits, and Accumulated Premiums", based on the assumptions
     stated in the illustrations are consistent with the provisions of the
     Contract. The rate structure of the Contract has not been designed so as to
     make the relationship between premiums and benefits, as shown in the
     illustrations, appear more favorable to the prospective purchaser of a
     Contract issued on a male age 55 and a female age 50, than to prospective
     purchasers of Contracts of different combinations of age, sex, or smoking
     status.

2.   The graphs included in the section of the prospectus entitled "Type of
     Insurance Amount", based on the assumptions stated in the illustrations,
     are consistent with the provisions of the Contract.

3.   The examples shown in the section of the prospectus entitled "Changing the
     Type of Insurance Amount" are consistent with the provisions of the
     Contract.

4.   The charts included in the sections of the prospectus "How a Fixed
     Insurance Amount Contract's Death Benefit Will Vary" and "How a Fixed
     Insurance Amount Contract's Death Benefit Will Vary" are consistent with 
     the provisions of the Contract.
    

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Page Two
December 15, 1995

5.   The deduction in an amount equal to 1.25% of each premium is a reasonable
     charge in relation to the additional income tax burden imposed upon The
     Prudential Insurance Company of America as the result of the enactment of
     Section 848 of the internal Revenue Code. In reaching that conclusion, a
     number of factors were taken into account that, in my opinion, were
     appropriate and which resulted in a project after-tax rate of return that
     is a reasonable rate to use in discounting the tax benefit of the
     deductions allowed in Section 8328 in taxable years subsequent to the year
     in which the premiums are received.

I hereby consent to the use of this opinion as an exhibit to the Registration
Statement and to the reference to my name under the heading "Experts" in the
prospectus.


Very truly yours,


Andy Mirchuk

svul.pru

    

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