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                                                                     Exhibit 8.1

                     [Andrews & Kurth L.L.P. Letterhead]




                                May 22, 1997



FIRSTPLUS INVESTMENT CORPORATION
3773 Howard Hughes Parkway, Suite 300N
Las Vegas, Nevada 89109


        Re:     FIRSTPLUS INVESTMENT CORPORATION
                Registration Statement on Form S-3

                
Ladies and Gentlemen:

        We have acted as special counsel for FIRSTPLUS INVESTMENT CORPORATION,
a corporation organized under the laws of the State of Nevada (the "Company"),
and certain trusts, all of the beneficial ownership of which will be initially
owned by the Company (each, an "Issuer"), in connection with the proposed
issuance by each Issuer or the Company of Asset Backed Certificates (the
"Certificates") or Asset Backed Notes (the "Notes"). The Certificates of a
series are to be issued pursuant to (i) a Pooling and Servicing Agreement
(each, a "Pooling and Servicing Agreement") between the Company, the servicer
(the "Servicer") and the trustee (the "Trustee") or (ii) a Trust Agreement
(each, a "Trust Agreement") between the Issuer, a special purpose entity to be
specified in such Trust Agreement (the "SPV"), and an owner trustee to be
specified therein (the "Owner Trustee").  The Notes of a series are to be
issued pursuant to an Indenture (each, an "Indenture") for such series, between
the applicable Issuer or the Company and the indenture trustee specified
therein (the "Indenture Trustee").  Forms of the Pooling and Servicing
Agreement, the Trust Agreement, and the Indenture have been filed with the
Securities and Exchange Commission as exhibits to the Company's registration
statement on Form S-3 (the "Registration Statement") filed on May 5, 1997
pursuant to the Securities Act of 1933, as amended (the "1933 Act").  This
opinion is also to be filed as an exhibit to the Registration Statement.

        We have examined originals or copies, certified or otherwise identified
to our satisfaction, of the Company's organizational documents; the Issuer's
form of organizational documents; the form of Pooling and Servicing Agreement
and the form of Certificates included therein; the form of Trust Agreement and
the form of Certificates included therein; the form of Indenture and the form
of Notes included therein; and such other documents, records, certificates of
the Company and the Issuer and public officials and other instruments as we
have deemed necessary for the purposes of 



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May 22, 1997
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rendering this opinion.  In addition, we have assumed that the Pooling and
Servicing Agreement or the Trust Agreement, as applicable,  as completed for
each series will be duly executed and delivered by each of the parties thereto;
that the Certificates as completed for each series will be duly executed and
delivered substantially in the forms contemplated by the Pooling and Servicing
Agreement or the Trust Agreement, as applicable; and that the Certificates for
each series will be sold as described in the Registration Statement.  We have
also assumed that the Indenture as completed for each series will be duly
executed and delivered by each of the parties thereto; that the Notes as
completed for each series will be duly executed and delivered substantially in
the forms contemplated by the Indenture; and that the Notes for each series
will be sold as described in the Registration Statement.

        On the basis of the foregoing and subject to the limitations and
qualifications set forth below, we are of the opinion that (i) the description
of federal income tax consequences appearing under the heading "Certain Federal
Income Tax Consequences" in the Prospectus contained in the Registration
Statement relating to Asset Backed Notes and Asset Backed Certificates
accurately describes the material federal income tax consequences to holders of
Certificates or Notes, as applicable, under existing law and subject to the
qualifications and assumptions stated therein and (ii) the description of
federal income tax consequences appearing under the heading "Certain Federal
Income Tax Consequences" in the Prospectus contained in the Registration
Statement relating to Asset Backed Certificates accurately describes the
material federal income tax consequences to holders of Certificates under
existing law and subject to the qualifications and assumptions stated therein.

        The opinions herein are based upon our interpretations of current law,
including court authority and existing Final and Temporary Regulations, which
are subject to change both prospectively and retroactively, and upon the facts
and assumptions discussed herein.  This opinion letter is limited to the
matters set forth herein, and no opinions are intended to be implied or may be
inferred beyond those expressly stated herein.  Our opinion is rendered as of
the date hereof and we assume no obligation to update or supplement this
opinion or any matter related to this opinion to reflect any change of fact,
circumstances, or law after the date hereof.  In addition, our opinion is based
on the assumption that the matter will be properly presented to the applicable
court.  Furthermore, our opinion is not binding on the Internal Revenue Service
or a court.  In addition, we must note that our opinion represents merely our
best legal judgment on the matters presented and that others may disagree with
our conclusion.  There can be no assurance that the Internal Revenue Service
will not take a contrary position or that a court would agree with our opinion
if litigated. In the event any one of the statements, representations or
assumptions we have relied upon to issue this opinion is incorrect, our opinion
might be adversely affected and may not be relied upon.

        We consent to the use and filing of this opinion as Exhibit 8.1 to the
Registration Statement and to the reference to our firm under the caption
"Legal Matters" in the Prospectus Supplement and 





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FIRSTPLUS INVESTMENT CORPORATION
May 22, 1997
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the Prospectus contained therein.  In giving such consent we do not  imply or
admit that we are an expert with respect to any part of the Registration
Statement, including this exhibit, within the meaning of the term "expert" as
used in the Securities Act or the rules and regulations of the Securities and
Exchange Commission thereunder.  This opinion is delivered as of the date
hereof and we disclaim any responsibility to update this opinion at any time
following the date hereof.


                                                Very truly yours,

                                                /s/ Andrews & Kurth L.L.P.