EXHIBIT 8.1


                          [KIRKLAND & ELLIS LETTERHEAD]




                                 April 22, 2002



Joy Global Inc.
100 E. Wisconsin Avenue
Suite 2780
Milwaukee, Wisconsin  53202

         Re:   Joy Global Inc. Exchange Offer for $200,000,000 8 3/4% Senior
               Subordinated Notes due 2012 for up to $200,000,000 8 3/4% Series
               B Senior Subordinated Notes due 2012

Dear Ladies and Gentlemen :

         We have acted as special counsel to Joy Global Inc. (the "Company") and
each of the following entities who have guaranteed the Old Notes (as defined
below) and the Exchange Notes (as defined below): American Alloy Corporation,
Benefit, Inc., Dobson Park Industries Inc., Harnischfeger Corporation,
Harnischfeger Technologies, Inc., Harnischfeger World Services Corporation,
HCHC, Inc., HCHC UK Holdings, Inc., HIHC, Inc., Joy MM Delaware, Inc., Joy
Technologies Inc., JTI UK Holdings, Inc., RCHH, Inc., South Shore Corporation,
South Shore Development, LLC, and The Horsburgh & Scott Company (the
"Guarantors," and together with the Company, the "Registrants") in connection
with the proposed offer (the "Exchange Offer") to exchange an aggregate
principle amount of up to $200,000,000 8 3/4% Senior Subordinated Notes due 2012
(the "Old Notes") for up to $200,000,000 8 3/4% Series B Senior Subordinated
Notes due 2012 (the "Exchange Notes"), pursuant to a Registration Statement on
Form S-4 filed with the Securities and Exchange Commission (the "Commission")
under the Securities Act of 1933, as amended (the "Securities Act"). Such
Registration Statement, as amended or supplemented, is hereinafter referred to
as the "Registration Statement." The Exchange Notes are to be issued pursuant to
the Indenture (the "Indenture"), dated as of March 18, 2002, by and among the
Registrants and Wells Fargo Bank Minnesota, N.A., as the Trustee, in exchange
for and in replacement of the Company's outstanding Old Notes, of which
$200,000,000 in aggregate principal amount are outstanding.

         You have requested our opinion as to certain United States federal
income tax consequences of the Exchange Offer. In preparing our opinion, we have
reviewed and relied upon the Registration Statement and such other documents as
we deemed necessary.






London              Los Angeles             New York            Washington, D.C.


                                KIRKLAND & ELLIS




Joy Global Inc.
April 22, 2002
Page 2


         On the basis of the foregoing, it is our opinion that the exchange of
the Old Notes for the Exchange Notes pursuant to the Exchange Offer will not be
treated as an "exchange" for United States federal income tax purposes, because
the Exchange Notes will not be considered to differ materially in kind or extent
from the Old Notes. Rather, the Exchange Notes received by a holder will be
treated as a continuation of the Old Notes in the hands of that holder.
Accordingly, there will be no federal income tax consequences to holders solely
as a result of the exchange of the Old Notes for Exchange Notes under the
Exchange Offer.

         The opinion set forth above is based upon the applicable provisions of
the Internal Revenue Code of 1986, as amended, the Treasury Regulations
promulgated or proposed thereunder, current positions of the Internal Revenue
Service (the "IRS") contained in published revenue rulings, revenue procedures
and announcements, existing judicial decisions and other applicable authorities.
No tax ruling has been sought from the IRS with respect to any of the matters
discussed herein. Unlike a ruling from the IRS, an opinion of counsel is not
binding on the IRS. Hence, no assurance can be given that the opinion stated in
this letter will not be successfully challenged by the IRS or that a court would
reach the same conclusion. We express no opinion concerning any tax consequences
of the Exchange Offer except as expressly set forth above.

         We consent to the filing of this opinion as an exhibit to the
Registration Statement, to the reference to this firm and to the inclusion of
our opinion in the section entitled "United States Federal Income Tax
Considerations" in the Registration Statement. In giving this consent, we do not
thereby admit that we are in the category of persons whose consent is required
under Section 7 of the Securities Act, or the rules and regulations of the
Securities and Exchange Commission promulgated thereunder.

                                        Very truly yours,

                                        /s/ KIRKLAND & ELLIS

                                        KIRKLAND & ELLIS