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                                                                     EXHIBIT 8.0

                  [Letterhead of Muldoon Murphy & Faucette LLP]



                                February 5, 2001


Board of Directors
BostonFed Bancorp, Inc.
17 New England Executive Park
Burlington, Massachusetts  01803

Ladies and Gentlemen:

     As special federal tax counsel to BFD Preferred Capital Trust II (the
"Issuer") and BostonFed Bancorp, Inc. in connection with the exchange offer by
the Issuer of $22,000,000 of its 10.875% Capital Securities, Series B ("Exchange
Capital Securities") pursuant to the prospectus (the "Prospectus") contained in
the Registration Statement for the Exchange Offer, and assuming the transactions
described in the Prospectus will be performed in accordance with the terms
described therein, we hereby confirm to you that, although the discussion set
forth under the heading "Material Federal Income Tax Consequences" in the
Prospectus does not purport to discuss all possible United States federal income
tax consequences of the purchase, ownership and disposition of Exchange Capital
Securities, in our opinion, such discussion constitutes, in all material
respects, a fair and accurate summary, in general terms, of the United States
federal income tax consequences of the purchase, ownership and disposition of
the Exchange Capital Securities, based upon laws as of the date hereof as they
relate to holders described therein. It is possible that contrary positions with
regard to the purchase, ownership and disposition of the Exchange Capital
Securities may be taken by the Internal Revenue Service and that a court may
agree with such contrary positions.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the references to us under the heading "Material
Federal Income Tax Consequences" in the Prospectus. In giving such consent, we
do not thereby admit that we are in the category of persons whose consent is
required under Section 7 of the Act.

                                      Very truly yours,


                                      MULDOON MURPHY & FAUCETTE LLP


                                      By: /s/ MULDOON MURPHY & FAUCETTE LLP