EXHIBIT 8.1
                (Blackwell Sanders Peper Martin LLP Letterhead)





                                December 11, 2003



Government Properties Trust, Inc.
10250 Regency Circle, Suite 100
Omaha, Nebraska 68114


      RE:   Tax Opinion in Connection with REIT Status of Government Properties
            Trust, Inc.

Ladies and Gentlemen:

         We have acted as tax counsel to Government Properties Trust, Inc., a
Maryland corporation (the "Company"), in connection with the preparation of its
Registration Statement on Form S-11 (the "Registration Statement"), relating to
the registration of Common Stock of the Company. You have requested our opinion
on certain Federal income tax matters in connection with the issuance of such
securities pursuant to the Registration Statement.

         In rendering this opinion, we have reviewed (i) the Registration
Statement; (ii) the Company's Articles of Incorporation; and (iii) the Company's
Bylaws. In our review, we have assumed the genuineness of all signatures, the
proper execution of all documents, the authenticity of all documents submitted
to us as originals, the conformity to originals of all documents submitted to us
as copies and the authenticity of the originals of any copies.

         For purposes of this opinion, with respect to matters of fact, we have
relied upon the representations of fact set forth in a certificate of an officer
of the Company (the "Officer's Certificate"). Although we have not independently
verified the truth, accuracy or completeness of the factual representations
contained in the Officer's Certificate and the underlying assumptions upon which
they are based, nothing has come to the attention of the attorneys primarily
responsible for the preparation of the Registration Statement, that would cause
them to question such representations.

         Based upon the foregoing, and the discussions in the Prospectus under
the caption "Material United States Federal Income Tax Consequences" (which are
incorporated herein by reference), we are of the opinion that: (1) based on the
Officer's Certificate and assuming the





                                                                           
  KANSAS CITY, MISSOURI o ST. LOUIS, MISSOURI o OVERLAND PARK, KANSAS o OMAHA, NEBRASKA
SPRINGFIELD, MISSOURI o EDWARDSVILLE, ILLINOIS o WASHINGTON, D.C. o LONDON, UNITED KINGDOM

 AFFILIATES: LEEDS o MANCHESTER o MEXICO CITY o MONTREAL o TORONTO o VANCOUVER





Government Properties Trust, Inc.
December 11, 2003
Page 2


Company operates as described in the Prospectus and the Officer's Certificate,
the Company's current and proposed organization and method of operation will
permit the Company to meet the requirements for taxation as a "real estate
investment trust" under the Internal Revenue Code of 1986, as amended, (the
"Code") for its taxable year ending December 31, 2003 and in future taxable
years; and (2) the statements made in the Registration Statement under the
caption "Material United States Federal Income Tax Consequences" to the extent
they describe matters of United States Federal income tax law provide an
accurate summary in all material respects of such provisions of the Federal
income tax law referred to therein.

         We note, however, that the ability of the Company to qualify as a real
estate investment trust for any year will depend upon future events, some of
which are not within the Company's control, and it is not possible to predict
whether the facts set forth in the Registration Statement, the Officer's
Certificate and this letter will continue to be accurate in the future. In
addition, our opinion is based on the Code, the Treasury regulations thereunder
(the "Regulations"), published rulings of the Internal Revenue Service (the
"Service"), cases or other relevant authority, and the status of the Company as
a real estate investment trust for Federal income tax purposes may be affected
by changes in the Code, the Regulations and other relevant authority.

         We consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to our firm under the captions
"Material United States Federal Income Tax Consequences" and "Legal Matters" in
the Prospectus included in the Registration Statement. By giving this consent,
we do not admit that we are within the category of persons whose consent is
required under Section 7 of the Securities Act of 1933, as amended, and the
rules and regulations promulgated thereunder.


                                          Very truly yours,

                                          /s/ Blackwell Sanders Peper Martin LLP