FOLEY & LARDNER
                         3000 K Street N.W., Suite 500
                          Washington, D.C. 20007-5143

                                                                       EXHIBIT 8



                                 April 24, 2002


Hanger Orthopedic Group, Inc.
7700 Old Georgetown Road
Bethesda, Maryland 20814

                  Re:      Form S-4 Registration Statement
                              Relating to 10 3/8% Senior Notes
                              Due 2009 Exchange Offer

Ladies and Gentlemen:

         We have acted as counsel to Hanger Orthopedic Group, Inc., a Delaware
corporation (the "Company"), in connection with the filing by the Company with
the Securities and Exchange Commission (the "Commission") today of a
Registration Statement on Form S-4 (the "Registration Statement") under the
Securities Act of 1933 (the "Securities Act"), relating to the proposed
issuance, in exchange for $200,000,000 aggregate principal amount of the
Company's outstanding, unregistered 10 3/8% Senior Notes due 2009 (the
"Unregistered Notes"), of $200,000,000 aggregate principal amount of the
Company's registered 10 3/8% Senior Notes due 2009 (the "Registered Notes"). The
Registered Notes are to be issued pursuant to an Indenture dated as of February
15, 2002, (the "Indenture") among the Company, its subsidiaries and Wilmington
Trust Company, as trustee (the "Trustee"). Capitalized terms used herein and not
defined have the meanings ascribed thereto in the Indenture.

         We hereby confirm that the statements set forth in Prospectus forming a
part of the Registration Statement under the caption "Certain United States
Federal Income Tax Consequences" accurately describe the material federal income
tax consequences to the holders of the Registered Notes issued pursuant to the
Prospectus.






Hanger Orthopedic Group, Inc.
April 24,  2002
Page 3



         This firm hereby consents to the reference to it under the heading
"Legal Matters" in the Prospectus and to the use of this opinion for filing as
Exhibit 8 to the Registration Statement.


                                                  Very truly yours,


                                                  Foley & Lardner