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                                                                       EXHIBIT 8


               [ARGUE PEARSON HARBISON & MYERS, LLP LETTERHEAD]


                                April 24, 1998



Omega Healthcare Investors, Inc.
905 W. Eisenhower Circle, Suite 110
Ann Arbor, MI 48103

                Re: TAX OPINION RE:  $50,000,000 SERIES B PREFERRED STOCK
                    $200,000,000 AGGREGATE OFFERING

Gentlemen:

        In connection with the Prospectus Supplement dated April 24, 1998 with
respect to the issuance by Omega Healthcare Investors, Inc. of $50,000,000 of
8.625% Series B Preferred Stock, you have requested our opinion concerning
whether the Company has been organized in conformity with the requirements for
qualification as a real estate investment trust, and whether its proposed
method of operation will enable it to meet the requirements for qualification
and taxation as a real estate investment trust under the Internal Revenue Code
of 1986, as amended (the "Code").

        The opinion is based on various facts and assumptions. We have also
been furnished with, and have relied upon, representations made by the Company
with respect to certain factual matters through a certificate of an officer of
the Company.

        Based on such facts, assumptions and representations, it is our opinion
(1) that the Company has been organized in conformity with the requirements for
qualification as a real estate investment trust under the Code, and its
proposed method of operation will enable it to meet the requirements for
qualification and taxation as a real estate investment trust under the Code,
and (2) the statements in the Prospectus Supplement dated April 24, 1998 set
forth under the caption "Certain Federal Income Tax Considerations" to the
extent such information constitutes matters of law, summaries of legal matters,
or legal conclusions, has been reviewed by us and is accurate in all material
respects. No opinion is expressed as to any matter not expressly addressed
herein.

        This opinion is based on various statutory provisions, regulations
promulgated thereunder and interpretations thereof by the Internal Revenue
Service and courts having jurisdiction over such matters, all of which are
subject to change either prospectively or retrospectively. Also, any variation
or difference in the facts from those set forth in the officer's certificate
furnished to us may affect the conclusions stated herein. Moreover, the
Company's qualification and taxation as a real estate investment trust depends
upon the Company's ability to meet, through actual annual operating results,
distribution levels and diversity of stock ownership, the various qualification
tests imposed
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Omega Healthcare Investors, Inc.
April 24, 1998
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under the Code, the results of which have not and will not be reviewed by Argue
Pearson Harbison & Myers, LLP.  Accordingly, no assurance can be given that the
actual results of the Company's operation for any one taxable year will satisfy
such requirements.

        This opinion is furnished to you solely for your use in connection with
the Registration Statement.  We hereby consent to the filing of this opinion as
an exhibit to the Registration Statement and to the use of our name under the
caption "Legal Matters" in the Prospectus Supplement.

                                        Very truly yours, 

                                        ARGUE PEARSON HARBISON & MYERS, LLP

                                        ARGUE PEARSON HARBISON & MYERS, LLP









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