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                                                                       EXHIBIT 8

                      B A S S, B E R R Y & S I M S  P L C
                    A PROFESSIONAL LIMITED LIABILITY COMPANY
                                ATTORNEYS AT LAW

2700 FIRST AMERICAN CENTER                       1700 RIVERVIEW TOWER
NASHVILLE, TENNESSEE 37238-2700                  POST OFFICE BOX 1509
TELEPHONE (615) 742-6200                         KNOXVILLE, TENNESSEE 37901-1509
TELECOPIER (615) 742-6293                        TELEPHONE (423) 521-6200
                                                 TELECOPIER (423) 521-6234


                                August 10, 1998


Board of Directors
First American Corporation
First American Center
Nashville, TN 37237-0700

Board of Directors
Peoples Bank
601 Highway 601, South
Dickson, Tennessee 37056

     RE:   FIRST AMERICAN CORPORATION
           REGISTRATION STATEMENT ON FORM S-4

Ladies and Gentlemen:

     We have acted as counsel to Peoples Bank, a Tennessee banking corporation
("Peoples"), in connection with a proposed reorganization to be effected
through a merger (the "Merger") of First American Interim Bank, a Tennessee
state-chartered bank ("Interim Bank") a wholly owned subsidiary of First
American Corporation, a Tennessee corporation ("First American"), with Peoples
being the surviving corporation, pursuant to the terms of the Agreement and
Plan of Merger dated as of April 21, 1998 between Peoples and First American
(the "Merger Agreement") and as described in the Registration Statement on Form
S-4 to be filed with the Securities and Exchange Commission today (the
"Registration Statement"). This opinion is being rendered pursuant to the
requirements of Item 21(a) of Form S-4 under the Securities Act of 1933, as
amended.

     In connection with this opinion, we have examined and are familiar with
originals or copies of (i) the Merger Agreement, (ii) the facts set forth in the
Registration Statement, and (iii) such other documents as we have deemed
necessary or appropriate in order to enable us to render the opinions below.
This opinion is subject to the receipt by us prior to the Effective Date of
certain written representations and covenants of Peoples, First American and
Interim Bank.

     Based upon and subject to the foregoing, in our opinion the discussion
contained in the prospectus included as part of the Registration Statement (the
"Prospectus") under the captions "Summary -- Federal Income Tax Consequences"
and "Certain Federal Income Tax Consequences," subject to the conditions and
limitations set forth therein, sets forth the material Federal income tax
consequences generally applicable to the Merger.

     The opinions expressed herein are expressly premised and conditioned upon
the consummation of the Merger pursuant to the terms and conditions of the
Merger Agreement. Our opinions are also based upon the application of existing
law to the instant transaction. You should note that future
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Board of Directors
Page 2
June 18, 1998


legislative changes, administrative pronouncements and judicial decisions could
materially alter the conclusions reached herein. There can be no assurance that
contrary positions may not be taken by the Internal Revenue Service or by the
courts. 

     This opinion is furnished to you solely for use in connection with the
Registration Statement. We hereby consent to the use of our name in the
Registration Statement and to the filing of this letter as an exhibit to the
Registration Statement. In giving such consent, we do not thereby admit that we
are in the category of persons whose consent is required under Section 7 of the
Securities Act of 1933, as amended, or the rules and regulations of the
Securities and Exchange Commission promulgated thereunder.

     We have rendered the foregoing opinion for the sole benefit and use of
First American, its Board of Directors, the shareholders of First American,
Peoples, its Board of Directors and the Peoples shareholders and the views
herein may not be relied upon or furnished to any other person without our prior
written consent.


                                       Sincerely,

                                       /s/ Bass, Berry & Sims PLC
 
                                       Bass, Berry & Sims PLC