EXHIBIT 8.1

                    [JAFFE, RAITT, HEUER & WEISS LETTERHEAD]


June 10, 2003


Sun Communities Operating Limited Partnership
27777 Franklin Rd., Suite 200
Southfield, MI  48034


         Re:      U.S. Federal Tax Considerations

Ladies and Gentlemen:

            We have acted as tax counsel to Sun Communities Operating Limited
Partnership, a Michigan limited partnership (the "Company"), in connection with
various legal matters relating to its filing of a Registration Statement on Form
S-4 on June 10, 2003 (together with all exhibits thereto and documents
incorporated by reference therein, the "Registration Statement"), under the
Securities Act of 1933, as amended (the "Securities Act"), covering $150,000,000
principal amount of 5.75% Notes due 2010 (the "Exchange Notes") of the Company
offered in exchange for a like principal amount of 5.75% Notes due 2010 (the
"Unregistered Notes") of the Company.

            You have requested our opinion concerning certain of the federal
income tax consequences to holders of the Unregistered Notes in connection with
the exchange described in the Registration Statement. This opinion is based on
various factual assumptions, including the facts set forth in the Registration
Statement concerning the business, properties and governing documents of the
Company, Sun Communities, Inc., a Maryland corporation, and their subsidiaries.

            In our capacity as tax counsel to the Company, we have made such
legal and factual examinations and inquiries, including an examination of
originals or copies certified or otherwise identified to our satisfaction of
such documents, corporate records and other instruments as we have deemed
necessary or appropriate for purposes of this opinion. For the purposes of our
opinion, we have not made an independent investigation or audit of the facts set
forth in the above referenced documents. In our examination, we have assumed the
authenticity of all documents submitted to us as originals, the genuineness of
all signatures thereon, the legal capacity of natural persons executing such
documents and the conformity to authentic original documents of all documents
submitted to us as copies.

            We are opining herein as to the effect on the subject exchange
transaction only of the federal income tax laws of the United States, and we
express no opinion with respect to the applicability to such transaction, or the
effect thereon, of other federal laws, the laws of any state






or other jurisdiction or as to any matters of municipal law or the laws of any
other local agencies within any state.

            Based on such facts, assumptions and representations, it is our
opinion that the statements in the Registration Statement set forth under the
caption "Certain U.S. Federal Tax Considerations" are, subject to the
limitations set forth therein, the material United States federal income tax
consequences relevant to holders of the Unregistered Notes of the exchange of
Unregistered Notes for Exchange Notes in the exchange offer pursuant to the
Registration Statement.

            No opinion is expressed as to any matter not discussed herein.

            This opinion is rendered to you as of the date of this letter, and
we undertake no obligation to update this opinion subsequent to the date hereof.
This opinion is based on various statutory provisions, regulations promulgated
thereunder and interpretations thereof by the Internal Revenue Service and the
courts having jurisdiction over such matters, all of which are subject to change
either prospectively or retroactively. Also, any variation or difference in the
facts from those set forth in the Registration Statement may adversely affect
the accuracy of the conclusions stated herein.

            We hereby consent to the filing of this as an exhibit to the
Registration Statement and to the reference to us in the Prospectus included as
part of the Registration Statement. In giving such consents, we do not hereby
admit that we are in the category of persons whose consent is required under
Section 7 of the Securities Act or the rules or regulations of the Securities
and Exchange Commission promulgated thereunder.


                   Very truly yours,


            /s/ Jaffe, Raitt, Heuer & Weiss, Professional Corporation