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                                 April 10, 1998




                                                                   EXHIBIT 8.1



Chancellor Media Corporation of Los Angeles
433 East Las Colinas Boulevard
Suite 1130
Irving, Texas  75039

         Re:   Registration Statement on Form S-4 (File No. 333-_____)

Dear Sir or Madam:

         You have requested our opinion concerning the material federal income
tax consequences of the exchange of 8-1/8% Senior Subordinated Notes due 2007,
Series B of Chancellor Media Corporation of Los Angeles (the "Company") which
have been registered under the Securities Act of 1933, as amended, for
outstanding 8-1/8% Senior Subordinated Notes due 2007, Series A of the Company,
in connection with the Registration Statement on Form S-4 filed herewith (the
"Registration Statement").

         The facts, as we understand them, and upon which with your permission
we rely in rendering the opinion expressed herein, are set forth in the
Registration Statement. Based on such facts, it is our opinion that the material
federal income tax consequences are accurately set forth under the heading
"Material United States Federal Income Tax Considerations" in the Registration
Statement. No opinion is expressed as to any matter not discussed therein.

         This opinion is based on various statutory provisions, regulations
promulgated thereunder and interpretations thereof by the Internal Revenue
Service and the courts having jurisdiction over such matters, all of which are
subject to change either prospectively or retroactively. Also, any variation or
difference in the facts from those set forth in the Registration Statement may
affect the conclusions stated herein.



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April 10, 1998
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         This opinion is rendered to you solely for use in connection with the
Registration Statement. We consent to your filing this opinion as an exhibit to
the Registration Statement, and to the reference to our firm under the headings
"Material United States Federal Income Tax Considerations" and "Legal Matters."


                                        Very truly yours,




                                        LATHAM & WATKINS