Exhibit 8.1



                         [KIRKLAND & ELLIS LETTERHEAD]


                                  May 22, 2002

Dura Operating Corp.
and each of the Guarantors
2791 Research Dr.
Rochester Hills, MI 48309


                  Re:      Dura Operating Corp.
                           Registration Statement on Form S-4

Ladies and Gentlemen:

                  We are issuing this opinion letter in our capacity as special
legal counsel to Dura Operating Corp., a Delaware corporation (the "Issuer"),
and each of the other guarantors listed on Schedule A hereto (such guarantors
are hereinafter referred to as the "Guarantors" and the Guarantors, together
with the Issuer, are hereinafter referred to as the "Registrants"), in
connection with the proposed offer by the Issuer (the "Exchange Offer") of up to
$350,000,000 in aggregate principal amount of the Issuer's 8 5/8% Senior Notes
due 2012, Series B (the "Exchange Notes") in exchange for and in replacement of
the Issuer's outstanding 8 5/8% Senior Notes due 2012 (the "Old Notes"),
pursuant to a Registration Statement filed with the Securities and Exchange
Commission (the "Commission") as of the date hereof, under the Securities Act of
1933, as amended (the "Act") (such Registration Statement, as amended or
supplemented, is hereinafter referred to as the "Registration Statement").

                  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 Issuer's Registration Statement and such
other documents as we have deemed necessary.

                  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 a taxable "exchange" for United States federal income tax
purposes because the Exchange Notes do not differ materially in kind or extent
from the Old Notes. The Exchange Notes received by a holder of Old Notes will be
treated as a continuation of the Old Notes in the hands of such holder and, as a
result, there will be no federal income tax consequences to such holder as a
result of such holder's exchange of Old Notes for Exchange Notes.






                  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
by a court. We express no opinion concerning any tax consequences of the
Exchange Offer except as expressly set forth above.

                  We hereby consent to the filing of this opinion as Exhibit 8.1
to the Registration Statement. We also consent to the reference to our firm
under the heading "Legal Matters." In giving this consent, we do not hereby
admit that we are in the category of persons whose consent is required under
Section 7 of the Act or the rules and regulations of the Commission promulgated
thereunder.

                                                     Sincerely,

                                                     /s/ KIRKLAND & ELLIS

                                                     Kirkland & Ellis






                                   SCHEDULE A
                                   ----------

Adwest Electronics, Inc.

Atwood Automotive Inc.

Atwood Mobile Products, Inc.

Dura Automotive Systems, Inc.

Dura Automotive Systems Cable Operations, Inc.

Dura Automotive Systems of Indiana, Inc.

Dura G.P.

Mark I Molded Plastics of Tennessee, Inc.

Universal Tool & Stamping Company Inc.