Exhibit 8.1

        [LETTERHEAD OF COOPERMAN LEVITT WINIKOFF LESTER & NEWMAN, P.C.]



                                    November 6, 1998


Coaxial Communications of Central Ohio, Inc.
Phoenix Associates
Insight Communications of Central Ohio, LLC
c/o Insight Communications Company, L.P.
126 E. 56th Street
New York, NY 10022

Ladies and Gentlemen:

     In our capacity as counsel to Coaxial Communications of Central Ohio, Inc.
("Coaxial"), an Ohio corporation, Phoenix Associates (collectively with Coaxial,
the "Issuers"), a Florida general partnership, and Insight Communications of
Central Ohio, LLC, a Delaware limited liability company, we have been requested
to furnish this opinion in connection with the registration statement (the
"Registration Statement") on Form S-4, filed concurrently herewith, with respect
to the registration of $140,000,000 aggregate principal amount of 10% Senior
Notes due 2006 of the Issuers (the "Exchange Notes") to be offered (the
"Exchange Offer") in exchange for outstanding 10% Senior Notes due 2006 (the
"Original Notes").

     We have made such examination as we have deemed necessary for the purpose
of this opinion. Based upon the terms of the Exchange Offer, the Original Notes
and the Exchange Notes, which are set forth in the Registration Statement, we
are of the opinion that the exchange of the Original Notes for Exchange Notes
pursuant to the Exchange Offer will not be treated as an "exchange" for federal
income tax purposes because the Exchange Notes will not (in our opinion) be
considered to differ materially in kind or extent from the Original Notes.
Rather, it is our opinion that the Exchange Notes received by a holder will be
treated as a continuation of the Original Notes in the hands of such holder and
that, consequently, there will be no federal income tax consequences to holders
exchanging Original Notes for Exchange Notes pursuant to the Exchange Offer.

     The foregoing opinion is based upon current provisions of the Internal
Revenue Code of 1986, as amended, the Treasury Regulations promulgated
thereunder, published pronouncements of the Internal Revenue Service, and case
law, any of which may be changed at any time with retroactive effect.  We
undertake no obligation to update this opinion in respect of any such changes.

 
     We hereby consent to the use of this opinion as an exhibit to the
Registration Statement and to the reference of our name under the caption "U.S.
Federal Income Tax Considerations" and "Legal Matters" in the prospectus
included in the Registration Statement.


                                    Very truly yours,


                                    COOPERMAN  LEVITT WINIKOFF
                                          LESTER & NEWMAN, P.C.


                                    By /s/  Mark Lubin
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