REID & PRIEST LLP 40 West 57th Street New York, NY 10019 New York, New York June 12, 1998 ICG Services, Inc. 161 Inverness Drive West Englewood, Colorado 80112 Ladies and Gentlemen: Reference is made to the prospectus, (the "Prospectus"), which constitutes part of the registration statement on Form S-4 ("Registration Statement"), to be filed by ICG Services, Inc. with the Securities and Exchange Commission on or about the date hereof pursuant to the Securities Act of 1933, as amended, for the exchange of 10% Senior Exchange Discount Notes due 2008 for an equal principal amount of newly-issued 10% Senior Exchange Discount Notes due 2008 (the "New Notes"). We are of the opinion that the statements set forth under the caption "Certain United States Federal Income Tax Considerations" in the Prospectus constitute an accurate description, in general terms, of certain United States federal income tax considerations that may be relevant to the prospective holders of the New Notes. We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the references to us in the Prospectus under the captions "Certain United States Federal Income Tax Considerations" and "Legal Matters." Very truly yours, /s/ Reid & Priest LLP REID & PRIEST LLP