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                                                                     EXHIBIT 8.1


            [NELSON MULLINS RILEY & SCARBOROUGH, L.L.P. LETTERHEAD]


                                  June 9, 1999


Forseon Corporation
6600 Jurupa Avenue
Riverside, CA 92504


Ladies and Gentlemen:

     With reference to the Registration Statement on Form S-4 (File No.
333-76493) ("Registration Statement") filed by Towne Services, Inc., a Georgia
corporation ("Towne Services"), with the Securities and Exchange Commission in
connection with the registration under the Securities Act of 1933, as amended,
of shares of its Common Stock, to be issued in connection with the transactions
contemplated by the Agreement and Plan of Merger (the "Merger Agreement") dated
as of March 25, 1999 by and among Towne Services, TSI Acquisition One, Inc., a
Georgia corporation and a wholly owned subsidiary of Towne Services, Forseon
Corporation, a Delaware corporation ("Forseon"), and Certain of the
Stockholders of Forseon, which Merger Agreement is described therein and filed
as an appendix to the Registration Statement, we hereby (1) confirm our opinion
set forth under the caption "Material Federal Income Tax Consequences" in the
Registration Statement, and (2) confirm that it is our opinion that the
discussion set forth under the captions "Summary -- Federal Income Tax
Consequences" and "Material Federal Income Tax Consequences" in the
Registration Statement describes the material federal income tax considerations
relevant to the Forseon stockholders receiving Towne Services Common Stock
pursuant to the Merger Agreement.

     We hereby consent to the filing of this opinion as Exhibit 8.1 to the
Registration Statement and to the use of our name in the Registration Statement
and in the Proxy Statement/Prospectus included therein.


                                  Very truly yours,

                                  /s/ Nelson Mullins Riley & Scarborough, L.L.P.

                                  Nelson Mullins Riley & Scarborough, L.L.P.