[Letterhead of Andrews & Kurth L.L.P.]

                                       January 10, 1997

National Propane Partners, L.P.
Suite 1700, IES Tower
200 1st Street, S.E.
Cedar Rapids, Iowa 52401-2067

                                   Tax Opinion

Gentlemen:

        We have acted as special counsel to National  Propane  Partners,  L.P, a
Delaware  limited  partnership  (the  "Partnership"),  in  connection  with  the
registration under the Securities Act of 1933, as amended (the "Act") of 400,000
common units  representing  limited partner  interests  ("Common  Units") in the
Partnership  which  may  be  sold  by  a  selling  unitholder  pursuant  to  the
Partnership's  registration  statement on Form S-1 filed with the Securities and
Exchange  Commission  on the date hereof  (the  "Registration  Statement").  The
Common Units will be sold or delivered by the selling unitholder, or transferees
affiliated  with it, from time to time in amounts,  at prices and on terms to be
determined  as  described  in  supplements  ("Prospectus  Supplements")  to  the
prospectus (the "Prospectus") contained in the Registration Statement.

        All statements of legal  conclusions  contained in the discussion  under
the caption "Tax  Considerations"  in the Prospectus,  unless  otherwise  noted,
represent our opinion with respect to the matters set forth therein.

        In  addition,  based on the  foregoing,  we are of the opinion  that the
federal income tax discussion in the Prospectus with respect to those matters as
to which no legal  conclusions  are provided is an accurate  discussion  of such
federal  income tax matters  (except for the  representations  and statements of
fact of the Partnership and its general  partners,  included in such discussion,
as to which we express no opinion).

        This  opinion is  delivered  as of the date hereof and we  disclaim  any
responsibility to update this opinion at any time following the date hereof.

 








National Propane Partners, L.P.
January 10, 1997

Page 2

        We  hereby  consent  to the  references  to our firm  and  this  opinion
contained in the Prospectus included in the Registration Statement.

                                                   Very truly yours,

                                                   Andrews & Kurth L.L.P.
                                                   425 Lexington Ave.
                                                   New York, NY 10017