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                                                                    EXHIBIT 8


                               KING & SPALDING

                             191 PEACHTREE STREET
                         ATLANTA, GEORGIA  30303-1763
                           TELEPHONE: 404/572-4600
                           FACSIMILE: 404/572-5100

DIRECT DIAL:                                                        DIRECT FAX:


                               October 23, 1997




Post Properties, Inc.
3350 Cumberland Circle
Suite 2200
Atlanta, Georgia 30339


      Re:    Post Properties, Inc. -- $50,000,000 Liquidation Preference of
             7 5/8% Series B Cumulative Redeemable Preferred Shares

Ladies and Gentlemen:

      We have acted as counsel to Post Properties, Inc., a Georgia corporation
(the "Company"), in connection with the registration under the Securities Act
of 1933, as amended, of $50,000,000 Liquidation Preference of 7 5/8% Series B
Cumulative Redeemable Preferred Shares of the Company (the "Series B Preferred
Shares") pursuant to a Prospectus Supplement dated October 23, 1997 (the
"Series B Preferred Shares Prospectus Supplement").  You have requested our
opinion as to the accuracy of the information contained in the Series B
Preferred Shares Prospectus Supplement under the heading "Certain Federal
Income Tax Considerations."

      Unless otherwise indicated, all terms used herein with the initial
capital letters shall have the same meaning as in the Series B Preferred Shares
Prospectus Supplement.

      In rendering the opinion expressed herein, we have examined such
documents as we have deemed appropriate.  In our examination of documents, we
have assumed, with your consent, that all documents submitted to us are
authentic originals, or if submitted as photocopies or telecopies, that they
faithfully reproduce the originals thereof, that all such documents have been
or will be duly executed to the extent required, that all representations and
statements set forth in such documents are true and correct, and that all
obligations imposed by any such documents on the parties thereto have been or
will be performed or satisfied in accordance with their terms.  We have also
obtained such additional information and representations as we have deemed
relevant and necessary through consultation with officers of the Company.
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October 23, 1997
Page 2




     Based upon and subject to the foregoing, we are of the opinion that the
information in the Series B Preferred Shares Prospectus Supplement under the
heading "Certain Federal Income Tax Considerations" constitutes, in all
material respects, a fair and accurate summary of the material United States
federal income tax consequences of the purchase, ownership and disposition of
the Series B Preferred Shares under current law.

     The opinion expressed herein is based upon the Internal Revenue Code of
1986, as amended, the U.S. Treasury Regulations promulgated thereunder, current
administrative positions of the U.S. Internal Revenue Service, and existing
judicial decisions, any of which could be changed at any time, possibly on a
retroactive basis.  Any such changes could adversely affect the opinion
rendered herein and the tax consequences to the Company and the investors in
the Series B Preferred Shares.  In addition, as noted above, our opinion is
based solely on the documents that we have examined, the additional information
that we have obtained, and the representations that have been made to us, and
cannot be relied upon if any of the facts contained in such documents or in
such additional information is, or later becomes, inaccurate or if any of the
representations made to us is, or later becomes, inaccurate.  We are not,
however, aware of any facts or circumstances contrary to or inconsistent with
the information, assumptions, and representations upon which we have relied for
purposes of this opinion.

     Finally, our opinion is limited to the tax matters specifically covered
thereby, and we have not been asked to address, nor have we addressed, any
other tax consequences of an investment in the Series B Preferred Shares.

                                                Very truly yours,

                                                /s/ King & Spalding

                                                King & Spalding