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                                                                     EXHIBIT 8.1


                 [MITCHELL, SILBERBERG & KNUPP LLP LETTERHEAD]


                                 March 19, 1998



WFS Financial Auto Loans, Inc.
23 Pasteur Road
Irvine, California 92618

               Re:    WFS Financial 1998-A Owner Trust
                      Registration Statement on Form S-1

Dear Sirs and Madams:

               We have acted as legal counsel for WFS Financial Auto Loans,
Inc., a California corporation (the "Company"), in connection with the
preparation of the Company's Registration Statement, as amended, on Form S-1
under the Securities Act of 1933, as amended (the "Registration Statement"),
filed with the Securities and Exchange Commission relating to the issuance of
certain certificates (the "Certificates") representing undivided interests in
the WFS Financial 1998-A Owner Trust (the "Trust") and certain notes (the
"Notes" and together with the Certificates the "Securities") secured by the
assets of the Trust.

               In rendering the opinion set forth below, we have examined the
Registration Statement dated as filed on March 20, 1998 (the "Form S-1") and
such exhibits to the Form S-1 as we have considered necessary or appropriate for
the purposes of this opinion. In rendering this opinion, we have assumed that a
final version of the Form S-1 will become the effective Registration Statement
of the Company without material change in the facts stated, and that the
issuance of the Securities will be duly authorized by all necessary action and
duly executed substantially in the manner described in the Form S-1. In
rendering this opinion, we have relied upon certain representations regarding
the underlying facts set forth in the Form S-1, including the existence, nature
and sufficiency of the installment contracts which shall be held as assets of
the Trust, as set forth in certain certificates provided by officers of the
Company and by officers of Western Financial Bank and WFS Financial Inc. The
opinion set forth herein is expressly based upon such assumptions and
representations and upon the accuracy of those facts so assumed or represented.
With respect to the underlying facts, we have made only such factual inquiries
as we have deemed appropriate and have not independently verified any facts.


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WFS Financial Auto Loans, Inc.
March 19, 1998
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               Based upon and subject to the foregoing, and in reliance thereon
and subject to the assumptions, exceptions and qualifications set forth herein,
it is our opinion that the information contained in the Form S-1 under the
caption "Certain Federal Income Tax Consequences" and the caption "Certain
California Income Tax Consequences", to the extent that such information
constitutes matters of law or legal conclusions, is correct.

               The opinions expressed in this letter are based upon relevant
provisions of the Internal Revenue Code of 1986, as amended, the California
Revenue and Taxation Code, federal and state income tax regulations, and current
interpretations thereof as expressed in court decisions and administrative
determinations in effect on this date. All of these provisions, regulations and
interpretations are subject to changes which might result in substantial
modifications of our opinions, and we do not undertake to advise you of any such
modification. We caution that although the opinions expressed in this letter
represents our best legal judgment as to such matter, our opinions have no
binding effect on the Internal Revenue Service, the California Franchise Tax
Board or the courts.

               We have expressed no opinion as to other tax issues affecting the
Company, the purchasers of the Securities or any other participant to the
transactions described in the Form S-1. We expressly refrain from rendering any
opinion as to the tax laws of any state (or subdivision thereof) other than
California or any foreign country.

               We consent to the filing of this opinion with, and to the
reference to our firm under the caption "Legal Matters" in the Registration
Statement. In giving our consent, we do not hereby admit that we come within the
category of persons whose consent is required under Section 7 of the Securities
Act of 1933, as amended, or the rules and regulations thereunder. This opinion
is given as of the date hereof and we assume no obligation to advise you of
changes that may hereafter be brought to our attention.

                                            Very truly yours,


                                            /S/ MITCHELL, SILBERBERG & KNUPP LLP

                                            MITCHELL, SILBERBERG & KNUPP LLP