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                                                                       EXHIBIT 8

                                 April 24, 1998



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

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 1,146,379 shares of Common Stock of the
Company (the "Shares") pursuant to a Prospectus Supplement dated April 23, 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 April 24, 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 opinions expressed herein, we have examined such
documents as we have deemed appropriate, including (but not limited to) the
Registration Statement to which the Prospectus Supplement relates and the
analyses of qualifying income prepared by the Company with the assistance of
Price Waterhouse LLP, the Company's accountants.  We have also examined the
organizational documents, as amended, of the following entities:  the Company,
the Operating Partnership, Post Development Services Limited Partnership,
Addison Circle One, Ltd., Addison Circle Two, Ltd., Rice Lofts, L.P., Post Rice
Lofts, LLC, Post Uptown, LLC, Akard-McKinney Investment Company, LLC, Columbus
Management Services, LLC, Post Mississippi Properties, LLC, Post Knox Park, LLC,
Greenwood Residential, LLC, Uptown Denver, LLC, Post Services, Inc. and Addison
Circle Access, Inc.  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 
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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 also have obtained such additional information
and representations as we have deemed relevant and necessary through
consultation with officers of the company and with Price Waterhouse LLP,
including representations from the Company in a letter to us of even date
herewith.

         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,


                                    King & Spalding