Exhibit 8.1


                     [Letterhead of Meserli & Kramer P.A.]


February 7, 2003

The Board of Governors
Granite Falls Community Ethanol Plant, LLC
2448-540th Street, Suite 1
Granite Falls, Minnesota  56241

     RE:      2002 Registration Statement Tax Matters

Ladies and Gentlemen:

As counsel for Granite Falls Community Ethanol Plant, LLC (the "Company"), we
furnish the following opinion in connection with the proposed issuance by the
Company of up to 30,000 of its membership units (the "Units").

We have acted as legal counsel to the Company in connection with its offering of
the Units. As such, we have participated in the preparation and filing with the
Securities and Exchange Commission under the Securities Act of 1933, as amended,
of a Form SB-2 Registration Statement originally dated August 30, 2002 relating
to that offering (the "Registration Statement").

You have requested our opinion as to the material federal income tax
consequences of owning the Units of the Company. For purposes of our opinion, we
are assuming that the offering will be completed, that facts will occur and that
the Company will conduct its operations in the manner described in the
Registration Statement. We have examined the Registration Statement and such
other documents as we have deemed necessary to render our opinion expressed
below.

Based on the foregoing, it is our opinion that Granite Falls Community Ethanol
Plant, LLC will be treated as a partnership for federal income tax purposes. Our
opinion is based on existing law as contained in the Internal Revenue Code of
1986, as amended, Treasury Regulations, administrative rulings and court
decisions as of the date of this opinion, all of which are subject to change.
Subsequent changes in these authorities may cause the tax treatment of Granite
Falls Community Ethanol Plant, LLC for federal income tax purposes to change.

This opinion will also confirm as correct our representation to you that the
statements of law, legal conclusions and general discussion regarding the
material federal income tax consequences of owning Units in the Company
contained in the Registration Statement under the Heading "Income Tax
Consequences of Owning Our Membership Units" are accurate in all material
respects, subject to the assumptions and qualifications set forth in that
section. That section of the Registration Statement is a general description of
the principal federal income tax consequences that are expected to arise from
the ownership and disposition of the Units, insofar as it relates to matters of
law and legal conclusions, which addresses material federal income tax
consequences to prospective unit holders relating to the ownership and
disposition of the Units. With limited exceptions, the discussion relates only
to individual citizens and residents of the United States and has limited
applicability to corporations, trusts, estates or nonresident aliens. The
discussion extends only to matters of law and legal conclusions with respect to
the general federal income tax consequences of owning Units in the Company based
on the assumptions and qualifications set forth therein, and does not extend to
matters of fact. The foregoing sentence does not apply to our opinion on the tax
status of Granite Falls Community Ethanol Plan, LLC.

An opinion of legal counsel represents an expression of legal counsel's
professional judgment regarding the subject matter of the opinion. It is neither
a guarantee of the indicated result nor is an undertaking to defend the
indicated result should it be challenged by the Internal Revenue Service. This
opinion is in no way binding on the Internal Revenue Service or on any court of
law.

We consent to the filing of this opinion as an exhibit to the Registration
Statement and to the reference to our firm in the Registration Statement.

Very truly yours,


/s/ Messerli & Kramer P.A.

MESSERLI & KRAMER P.A.