1
                                                                       EXHIBIT 8


                          [KING & SPALDING LETTERHEAD]


                               February 24, 1998


Post Properties, inc.
Suite 2200
3350 Cumberland Circle
Atlanta, Georgia 30309

         Re:      Post Properties, Inc. -- Common Stock

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 3,000,000 shares of Common Stock of the
Company (the "Shares") pursuant to a Prospectus Supplement dated February 12,
1998 (the "Prospectus Supplement"). You have requested our opinion as to the
accuracy of the information contained in the Prospectus Supplement under the
heading "Federal Income Tax Considerations."

         We understand that our opinion will be attached as an exhibit to the
Company's Current Report on Form 8-K, which will be filed with the Securities
and Exchange Commission on February 25, 1998. We hereby consent to such use of
our opinion.

         Unless otherwise indicated, all terms used herein with initial capital
letters shall have the same meaning as in the 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.
   2
Post Properties, Inc.
February 24, 1998
Page 2



We also have obtained such additional information and representations as we
have deemed relevant and necessary through consultation with officers of the
Company.

         Based upon and subject to the foregoing, we are of the opinion that
the information in the Prospectus Supplement under the heading "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 Shares under current law, and, to
the extent such discussion contains statements of law or legal conclusions,
such statements and conclusions are the opinion of King & Spalding.

         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 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 Shares.

                                             Very truly yours,

                                             /s/ King & Spalding

                                             King & Spalding