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                                                                     Exhibit 8.1




                   [Letterhead of Jones, Day, Reavis & Pogue]


                               November 26, 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
material federal income tax consequences of the Merger to holders of Fieldcrest
Common Stock and Fieldcrest Preferred Stock are as follows:  (i) the receipt by
a Fieldcrest stockholder of the merger consideration (including any cash
amounts received by dissenting stockholders pursuant to the exercise of
appraisal rights) in exchange for shares of Fieldcrest Common Stock or
Fieldcrest Preferred Stock will be a taxable transaction for federal income tax
purposes; (ii) for federal income tax purposes, a stockholder will recognize
gain (or loss) equal to the difference between (a) the sum of the amount of
cash and the fair market value of the Pillowtex Common Stock received pursuant
to the Merger and (b) the tax basis of the shares of Fieldcrest Common Stock or
Fieldcrest Preferred Stock exchanged pursuant to the Merger; (iii) gain (or
loss) must be determined separately for each block of shares of Fieldcrest
Common Stock or Fieldcrest Preferred Stock (i.e., shares acquired at the same
cost in a single transaction) converted to shares of Pillowtex Common Stock and
cash in the Merger; (iv) assuming that such shares of Fieldcrest Common Stock
or Fieldcrest Preferred Stock constitute capital assets in the stockholder's
hands, such gain (or loss) will be long-term gain (or loss) if, at the
Effective Time, the shares of Fieldcrest Common Stock or Fieldcrest Preferred
Stock were held for more than one year; (v) the recently enacted Taxpayer
Relief Act of 1997 reduces the rate of federal income tax imposed on capital
gains with respect to capital assets held more than 18 months by noncorporate
taxpayers; and (vi) the basis of the Pillowtex Common Stock received pursuant
to the Merger will be its fair market value at the time of the Merger, and the
holding period thereof will begin on the day following the day on which the
Effective Time occurs. 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