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                                                                     EXHIBIT 8.2
 
                [CLEARY, GOTTLIEB, STEEN & HAMILTON LETTERHEAD]
 
                                January 13, 1998
 
Coast Savings Financial, Inc.
1000 Wilshire Boulevard
Los Angeles, California 90017-2457
 
Ladies and Gentlemen:
 
     We have acted as special counsel to Coast Savings Financial, Inc. in
connection with the Registration Statement of H.F. Ahmanson & Company on Form
S-4 filed with the Securities and Exchange Commission on January 13, 1998 (the
"Registration Statement") and hereby confirm to you our opinion, set forth under
the heading "THE MERGER -- Certain Federal Income Tax Consequences" in the Proxy
Statement/ Prospectus included in the Registration Statement, under currently
applicable law.
 
     We hereby consent to the use of our name and the making of statements with
respect to us under the caption "THE MERGER -- Certain Federal Income Tax
Consequences" in the Proxy Statement/Prospectus and to the incorporation by
reference of this opinion (and consent) in a registration statement to be filed
by Ahmanson pursuant to Rule 462(b) under the Securities Act of 1933, as
amended.
 
     In giving this consent, we do not hereby 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 thereunder.
 
                                          Very truly yours,
 
                                          CLEARY, GOTTLIEB, STEEN & HAMILTON
 
                                          By:     /s/  JAMES M. PEASLEE
                                            ------------------------------------
                                                James M. Peaslee, a Partner