.
.
.
EXHIBIT 8.1

BASS, BERRY & SIMS PLC
A PROFESSIONAL LIMITED LIABILITY COMPANY
ATTORNEYS AT LAW
KNOXVILLE OFFICE DOWNTOWN OFFICE:
900 SOUTH GAY STREET, SUITE 1700 REPLY TO: AMSOUTH CENTER
KNOXVILLE, TN 37902 AMSOUTH CENTER 315 DEADERICK STREET, SUITE 2700
(865) 521-6200 315 DEADERICK STREET, SUITE 2700 NASHVILLE, TN 37238-3001
NASHVILLE, TN 37238-3001 (615) 742-6200
MEMPHIS OFFICE (615) 742-6200
THE TOWER AT PEABODY PLACE MUSIC ROW OFFICE:
100 PEABODY PLACE, SUITE 950 WWW.BASSBERRY.COM 29 MUSIC SQUARE EAST
MEMPHIS, TN 38103-2625 NASHVILLE, TN 37203-4322
(901) 543-5900 (615) 255-6161

January 9, 2004

Gaylord Entertainment Company
One Gaylord Drive
Nashville, Tennessee 37214

Re: Offer for All Outstanding 8% Senior Notes Due 2013 of Gaylord
Entertainment Company in Exchange for 8% Senior Notes Due 2013 of
Gaylord Entertainment Company - Registration Statement on Form S-4

Ladies and Gentlemen:

We have acted as counsel to Gaylord Entertainment Company, a Delaware
corporation (the "Company"), and the Guarantors (as defined below) in connection
with the public offering of up to $350,000,000 aggregate principal amount of 8%
Senior Notes Due 2013 (the "New Notes") of the Company that are to be guaranteed
on an unsecured senior basis (the "Guarantees") by the subsidiaries of the
Company listed on Schedule I attached hereto (the subsidiary guarantors set
forth on Schedule I attached hereto being collectively referred to herein as the
"Guarantors"). The New Notes are to be issued pursuant to an exchange offer (the
"Exchange Offer") in exchange for a like principal amount and denomination of
the Company's issued and outstanding 8% Senior Notes Due 2013 (the "Old Notes"),
as contemplated by the Registration Rights Agreement dated as of November 12,
2003 (the "Registration Rights Agreement"), by and among the Company, the
Guarantors, Banc of America Securities LLC, Deutsche Bank Securities, Inc., CIBC
World Markets Corp., Fleet Securities, Inc. and Citigroup Global Markets Inc.
The Old Notes were issued, and the New Notes will be issued, under an Indenture,
dated as of November 12, 2003, as supplemented by Supplemental Indenture dated
November 20, 2003 (collectively, the "Indenture"), by and among the Company, the
Guarantors and U.S. Bank National Association as Trustee (the "Trustee").

In connection with this opinion, we have examined originals or copies,
certified or otherwise identified to our satisfaction, of (i) the Registration
Statement on Form S-4 of the Company relating to the Exchange Offer, as filed
with the Securities and Exchange Commission (the "Commission") on January 9,
2004 (such Registration Statement, as amended to date, being hereinafter
referred to as the "Registration Statement"); (ii) an executed copy of the
Registration Rights Agreement; (iii) an executed copy of the Indenture; (iv) the
Form T-1 of the Trustee filed as an exhibit to the Registration Statement; (v)
the form of the New Notes; and (vi) executed copies of the Guarantees. We also
have examined and relied upon originals or copies, certified or otherwise
identified to our satisfaction, of such records, documents, certificates and
other instruments as in our judgment are necessary or appropriate in order to
express the opinions hereinafter set forth.

Gaylord Entertainment Company
January 9, 2004
Page 2

Based on the foregoing, the statements in the Registration Statement
set forth under the caption "Material U.S. Federal Income Tax Considerations,"
constitute our opinion of the material U.S. federal income tax considerations
applicable to the offering of the New Notes. In arriving at the opinion
expressed above, we have assumed that the New Notes will be duly executed and
delivered in substantially the forms set forth in the Indenture and will be
issued as described in the Registration Statement.

You should be aware that the above opinions are based on our
interpretations of current law, including court authority and existing final and
temporary U.S. Treasury regulations, which law is subject to change both
prospectively and retroactively. Our opinions are not binding on the Internal
Revenue Service or a court and there can be no assurance that the Internal
Revenue Service will not take a contrary position or that a court would agree
with our opinions if litigated. Our opinion is rendered as of the date hereof
and we assume no obligation to update or supplement this opinion or any matter
related to this opinion to reflect any change of fact, circumstances or law
after the date hereof. In the event any one of the statements, representations
or assumptions we have relied upon to issue this opinion is incorrect, our
opinion may be adversely affected.

This opinion is rendered solely in connection with the Registration
Statement. We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement. We also consent to all references to Bass, Berry & Sims
PLC included in or made part of the Registration Statement and to the discussion
of our opinion in the Registration Statement. In giving this consent, we do not
admit that we are in the category of persons whose consent is required by
Section 7 of the Securities Act of 1933, as amended, or the rules and
regulations promulgated thereunder by the Securities and Exchange Commission.
This opinion may not be relied upon for any other purpose.

No opinion has been sought and none has been given concerning the tax
treatment of the issuance and sale of the Notes under the laws of any other
country or any state or locality.

Very truly yours,

/s/ Bass, Berry & Sims PLC

SCHEDULE I

LIST OF GUARANTORS

STATE OR OTHER JURISDICTION OF
INCORPORATION OR ORGANIZATION AND
NAME OF GUARANTOR FORM OF ORGANIZATION
- -------------------------------------------------------- ---------------------------------------

CCK Holdings, LLC Delaware limited liability company
Corporate Magic, Inc. Texas corporation
Gaylord Creative Group, Inc. Delaware corporation
Gaylord Hotels, LLC Delaware limited liability company
Gaylord Investments, Inc. Delaware corporation
Gaylord Program Services, Inc. Delaware corporation
Grand Ole Opry Tours, Inc. Tennessee corporation
OLH, G.P. Tennessee general partnership
OLH Holdings, LLC Delaware limited liability company
Opryland Attractions, Inc. Delaware corporation
Opryland Hospitality, LLC Tennessee limited liability company
Opryland Hotel-Florida Limited Partnership Florida limited partnership
Opryland Hotel-Texas Limited Partnership Delaware limited partnership
Opryland Hotel-Texas, LLC Delaware limited liability company
Opryland Productions, Inc. Tennessee corporation
Opryland Theatricals, Inc. Delaware corporation
Wildhorse Saloon Entertainment Ventures, Inc. Tennessee corporation
ResortQuest International, Inc. Delaware corporation
Abbott & Andrews Realty, LLC Florida limited liability company
Abbott Realty Services, Inc. Florida corporation
Abbott Resorts, LLC Florida limited liability company
Accommodations Center, Inc. Colorado corporation
Advantage Vacation Homes by Styles, LLC Florida limited liability company
B&B on the Beach, Inc. North Carolina corporation
Base Mountain Properties, Inc. Delaware corporation
Bluebill Properties, LLC Florida limited liability company
Brindley & Brindley Realty & Development, Inc. North Carolina corporation
Coastal Real Estate Sales, LLC Florida limited liability company
Coastal Resorts Management, Inc. Delaware corporation
Coastal Resorts Realty, L.L.C. Delaware limited liability company
Coates, Reid & Waldron, Inc. Delaware corporation
Collection of Fine Properties, Inc. Colorado corporation
Columbine Management Company Colorado corporation
Cove Management Services, Inc. California corporation
CRW Property Management, Inc. Delaware corporation
Exclusive Vacation Properties, Inc. Delaware corporation
First Resort Software, Inc. Colorado corporation
High Country Resorts, Inc. Delaware corporation
Houston and O'Leary Company Colorado corporation
K-T-F Acquisition Co. Delaware corporation
Maui Condominium and Home Realty, Inc. Hawaii corporation
Mountain Valley Properties, Inc. Delaware corporation
Office and Storage LLC Hawaii limited liability company
Peak Ski Rentals LLC Colorado limited liability company
Plantation Resort Management, Inc. Delaware corporation
Priscilla Murphy Realty, LLC Florida limited liability company
R&R Resort Rental Properties, Inc. North Carolina corporation

REP Holdings, Ltd. Hawaii corporation
Resort Property Management, Inc. Utah corporation
ResortQuest Hawaii, LLC Hawaii limited liability company
ResortQuest Hilton Head, Inc. Delaware corporation
ResortQuest Southwest Florida, LLC Delaware limited liability company
Ridgepine, Inc. Delaware corporation
RQI Holdings, Ltd. Hawaii corporation
Ryan's Golden Eagle Management, Inc. Montana corporation
Scottsdale Resort Accommodations, Inc. Delaware corporation
Steamboat Premier Properties, Inc. Delaware corporation
Styles Estates, LLC Florida limited liability company
Telluride Resort Accommodations, Inc. Colorado corporation
Ten Mile Holdings, Ltd. Colorado corporation
THE Management Company Georgia corporation
The Maury People, Inc. Massachusetts corporation
The Tops'l Group, Inc. Florida corporation
Tops'l Club of NW Florida, LLC Florida limited liability company
Trupp-Hodnett Enterprises, Inc. Georgia corporation