Exhibit 8.1

                    Skadden, Arps, Slate, Meagher, & Flom LLP
                                Four Times Square
                          New York, New York 10036-6522

                                                                October 11, 2001

CBNY Investment Services Corp.
320 Park Avenue
New York, New York 10022

Ladies and Gentlemen:


     We have acted as special counsel to CBNY Investment Services Corp., a New
York corporation (the "Company"), in connection with the preparation of the
Registration Statement on Form S-1 (Registration No. 333-61212) originally filed
with the Securities and Exchange Commission on May 18, 2001 (the "Registration
Statement"), as amended, relating to the offering to holders of Commercial Bank
of New York ("CBNY") common stock of subscription rights to purchase up to
1,060,000 shares of the Company's common stock (the "Rights Offering").


     In connection with this opinion, we have examined and relied on originals
or copies, certified or otherwise identified to our satisfaction, of (i) the
Registration Statement, (ii) the Agreement and Plan of Reorganization, dated as
of February 13, 2001, by and among CBNY, North Fork Bancorporation, Inc. and
North Fork Bank (the "Merger Agreement"), and (iii) such other documents,
certificates, and records as we have deemed necessary or appropriate as a basis
for the opinion set forth herein. We have also relied upon factual statements
and representations made to us by representatives of the Company, CBNY and
others. For purposes of this opinion, we have assumed the validity and accuracy
of the documents, certificates, records, statements, and representations
referred to above. We have also assumed that the Rights Offering will be
consummated in accordance with the Merger Agreement, the Registration Statement
and such other documents, certificates and records and that the statements as to
factual matters contained in the Registration Statement are true, correct and
complete and will continue to be true, correct and



CBNY Investment Services Corp.
October 11, 2001
Page 2


complete through the completion of the Rights Offering.


     In our examination, we have assumed the legal capacity of all natural
persons, the genuineness of all signatures, the authenticity of all documents
submitted to us as originals, the conformity to original documents of all
documents submitted to us as certified, conformed or photostatic copies, and the
authenticity of the originals of such copies. In making our examination of
documents executed, or to be executed, by the parties indicated therein, we have
assumed that each party (other than the Company and CBNY) has, or will have, the
power, corporate or other, to enter into and perform all obligations thereunder
and we have also assumed the due authorization by all requisite action,
corporate or other, and the execution and delivery by such parties and the
validity and binding effect thereof on such parties.


     In rendering our opinion, we have considered the applicable provisions of
the Internal Revenue Code of 1986, as amended, Treasury Department regulations
promulgated thereunder, pertinent judicial authorities, interpretive rulings of
the Internal Revenue Service and such other authorities as we have considered
relevant. It should be noted that statutes, regulations, judicial decisions and
administrative interpretations are subject to change at any time (possibly with
retroactive effect). A change in the authorities or the accuracy or completeness
of any of the information, documents, certificates, records, statements,
representations, covenants, or assumptions on which our opinion is based could
affect our conclusions.

     On the basis of and subject to the foregoing, we hereby confirm that the
opinion of counsel set forth in the Registration Statement under the heading
"MATERIAL UNITED STATES FEDERAL INCOME TAX CONSEQUENCES" is the opinion of
Skadden, Arps, Slate, Meagher & Flom LLP, based upon current United States
federal income tax law. There can be no assurances, however, that such opinion
will be accepted by the Internal Revenue Service or, if challenged, by a court
of law.


     Except as set forth above, we express no opinion to any party as to the tax
consequences, whether federal, state, local or foreign, of the Rights Offering
or of any transaction related thereto or contemplated thereby. This opinion is
expressed as of the date hereof, and we are under no obligation to advise you
of, supplement or


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CBNY Investment Services Corp.
October 11, 2001
Page 3


revise our opinion to reflect, any changes (including changes that have
retroactive effect) in applicable law or any information, document, certificate,
record, statement, representation, covenant or assumption relied upon herein
that becomes incorrect or untrue. We hereby consent to the use of our name in
the sections captioned "MATERIAL UNITED STATES INCOME TAX CONSEQUENCES" and
"LEGAL MATTERS" in the Registration Statement. In giving this consent, we do not
admit that we come within the category of persons whose consent is required
under Section 7 of the Securities Act of 1933, as amended, or the Rules and
Regulations of the Securities and Exchange Commission thereunder.



                                 Very truly yours,

                                 /s/ Skadden, Arps, Slate, Meagher, & Flom LLP



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