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                                                                       EXHIBIT 8


                                October 29, 1998



Post Properties, Inc.
One Riverside
4401 Northside Parkway, Suite 800
Atlanta, Georgia 30327-3057


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 (the "1933 Act,"), of 1,000,000 shares of Common Stock of the
Company (the "Shares") pursuant to a Prospectus Supplement dated October 29,
1998 (the "Prospectus Supplement"). You have requested our opinion as to the
accuracy of the information contained in Prospectus Supplement under the heading
"Certain 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 (the "Commission") on or about November 2, 1998. We
hereby consent to such use of our opinion. 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 1933 Act.

     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, including (but not limited to) the Registration
Statement on Form S-3 (File No. 333-36595), including the reports incorporated
by reference therein, filed by the Company with the Commission on September 29,
1997, the Prospectus dated as of October 20, 1997, the Prospectus Supplement,
and the analyses of qualifying income prepared by the Company with the
assistance of PricewaterhouseCoopers, 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,
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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 original 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 
PricewaterhouseCoopers 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 "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 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 given as of the date hereof and 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