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                                                                    Exhibit 8.1




                   [Letterhead of Jones, Day, Reavis & Pogue]


                               November 12, 1997


Pillowtex Corporation
4111 Mint Way
Dallas, Texas  75237

          Re: Registration Statement on Form S-4 of Pillowtex Corporation

Gentlemen:

                  We have acted as counsel to Pillowtex Corporation (the
"Pillowtex") in connection with the Registration Statement on Form S-4 (the
"Registration Statement") to which this opinion appears as Exhibit 8.1 which
includes a Joint Proxy Statement/Prospectus (the "Joint Proxy
Statement/Prospectus") relating to the merger (the "Merger") of a wholly owned
subsidiary of Pillowtex with and into Fieldcrest Cannon, Inc. ("Fieldcrest").
Unless otherwise indicated, any defined terms used herein have the same meaning
as in the Joint Proxy Statement/Prospectus. We are of the opinion that the
section of the Joint Proxy Statement/Prospectus entitled "The Merger--Certain
Federal Income Tax Consequences" accurately summarizes the material federal
income tax consequences of the Merger to holders of Fieldcrest Common Stock and
Fieldcrest Preferred Stock. In connection with the foregoing opinion, we have
relied, without independent investigation, upon the completeness and accuracy
of the statements and representations of facts set forth in the Merger
Agreement and the Joint Proxy Statement/Prospectus.

                  We hereby consent to the filing with the Securities and
Exchange Commission of this opinion as an exhibit to the Registration Statement
and to the reference to us under the caption "The Merger--Certain Federal
Income Tax Consequences" in the Joint Proxy Statement/Prospectus.


                                         Very truly yours,

                                         /s/ Jones, Day, Reavis & Pogue

                                         Jones, Day, Reavis & Pogue