Exhibit 8.1


                         SIMPSON THACHER & BARTLETT LLP
                              425 LEXINGTON AVENUE
                            NEW YORK, NEW YORK 10017



                                                November 6, 2003


WCI Communities, Inc.
24301 Walden Center Drive
Bonita Springs, Florida 34134
(239) 947-2600


Ladies and Gentlemen:

        We have acted as counsel to WCI Communities, Inc., a Delaware
corporation (the "Company"), in connection with the preparation and filing by
the Company with the Securities and Exchange Commission of the Registration
Statement on Form S-3 dated September 12, 2003 under the Securities Act of
1933, as amended, (the "Registration Statement") with respect to the
registration of $125,000,000 aggregate principal amount of 4.0% Contingent
Convertible Senior Subordinated Notes due 2023 (the "Convertible Notes") issued
under the Indenture, dated as of August 5, 2003 between the Company and The
Bank of New York, a New York banking corporation, as trustee.

        In delivering this opinion letter, we have reviewed and relied upon:
(i) the Registration Statement; (ii) the Indenture; and (iii) forms of the
Convertible Notes.  We have also examined and relied upon originals, or
duplicates or certified or conformed copies, of such records of the Company and
such other documents, certificates and records as we have deemed necessary or
appropriate as a basis for the opinion set forth herein.

        In such examination, we have assumed the genuineness of all signatures,
the legal capacity of natural persons, the authenticity of all documents
submitted to us as originals, the conformity to original documents of all
documents submitted to us as certified or photostatic copies, and the
authenticity of the originals of such latter documents.

        Based upon the foregoing, and subject to the qualifications and
limitations stated herein and in the Registration Statement, we hereby confirm
our opinion set forth in the Registration Statement under the caption "Material
United States Federal Income Tax Considerations."

        We express no opinion with respect to the transactions referred to
herein or in the Registration Statement other than as expressly set forth
herein.

        We are members of the Bar of the State of New York, and we do not
express any opinion herein concerning any law other than the federal tax law of
the United States.

        We hereby consent to the use of our name in the Registration Statement
under the caption "Legal Matters."


                                              Very truly yours,



                                              /s/ Simpson Thacher & Bartlett LLP
                                              ----------------------------------
                                              SIMPSON THACHER & BARTLETT LLP