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                                                                     EXHIBIT 8.1



                                October 20, 1998



Home Interiors & Gifts, Inc.
4550 Spring Valley Road
Dallas, Texas 75244-3705


Ladies and Gentlemen:

         We have acted as counsel to Home Interiors & Gifts, Inc., a Texas
corporation (the "Company"), in connection with the preparation and filing with
the Securities and Exchange Commission of the Company's Registration Statement
(Registration No. 333-62021) on Form S-4 originally filed on August 21, 1998, as
amended to the date hereof (together with the exhibits thereto, the
"Registration Statement"), relating to the registration by the Company of its 
10 1/8% Senior Subordinated Senior Notes due 2008.

         In so acting, we have examined originals or copies, certified or
otherwise identified to our satisfaction, of the Registration Statement,
including the Prospectus which is a part thereof (the "Prospectus"), and such
corporate records, agreements, documents and other instruments (the
aforementioned documents together, the "Documents"), and have made such
inquiries of such officers and representatives, as we have deemed relevant and
necessary as a basis for the opinion hereinafter set forth. In such examination,
we have assumed the authenticity of all documents submitted to us as originals,
the conformity to original documents of all documents submitted to us as
certified or photostatic copies, the authenticity of the originals of such
latter documents, the genuineness of all signatures, and the correctness of all
representations made therein. (The terms of the Documents are incorporated
herein by reference.) We have further assumed that the final executed Documents
will be substantially the same as those which we have reviewed and that there
are no agreements or understandings between or among the parties to the
Documents with respect to the transactions contemplated therein other than those
contained in the Documents.









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Home Interiors & Gifts, Inc.
October 20, 1998
Page 2


         Based on the foregoing, subject to the next succeeding paragraph, and
assuming full compliance with all the terms of the Documents, it is our opinion
that the discussion included in the Prospectus under the caption "Certain
Federal Income Tax Considerations," insofar as it constitutes statements of law
or legal conclusions and except to the extent qualified therein, is accurate in
all material respects.

         The foregoing opinion is based on current provisions of the Internal
Revenue Code of 1986, as amended, the Treasury Regulations promulgated
thereunder, published pronouncements of the Internal Revenue Service, and case
law, any of which may be changed at any time with retroactive effect. No opinion
is expressed on any matters other than those specifically covered by the
foregoing opinion.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement.

                                        Very truly yours,

                                        /s/  WEIL, GOTSHAL, & MANGES LLP