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                                                            Exhibit 8


                                                                    216-586-3939




                                  July 10, 2000




The J. M. Smucker Company
Strawberry Lane
Orrville, Ohio  44667-0280


Ladies and Gentlemen:

                  You have requested our opinion regarding the material federal
income tax consequences of the exchange of Class A common shares, without par
value (the "Class A Shares"), and Class B common shares, without par value (the
"Class B Shares"), of The J. M. Smucker Company, an Ohio corporation (the
"Company"), for shares of a single class of new common shares, without par
value, of the Company (the "New Common Shares"), for cash, or for both New
Common Shares and cash (the "Exchange"), in the merger of JMS-Ohio, Inc., an
Ohio corporation ("JMS"), with and into the Company pursuant to an Agreement of
Merger, dated as of July 3, 2000, between the Company and JMS (the "Merger
Agreement").

                  This opinion addresses only the tax consequences of the
Exchange under the Internal Revenue Code of 1986, as amended (the "Code").
Capitalized terms used but not defined in this letter have the meanings given
them in the Merger Agreement.

                  In rendering this opinion, we have examined the Merger
Agreement, the registration statement on Form S-4 that includes the Company
proxy statement-prospectus prepared in connection with the Exchange (the
"Registration Statement"), and such other documents and records of the Company
and JMS as we have determined to be necessary or appropriate. With your consent,
we have also relied upon the accuracy at all material times of the assumptions
contained in a tax certification letter of the Company dated July 10, 2000. We
assume that the Merger Agreement and each of the other documents executed or
finalized in connection with the Exchange have not been, and will not be,
amended prior to the Effective Time and that the Exchange will be effected in
the manner described in the Merger Agreement and the Registration Statement. We
also assume that the Class A Shares and Class B Shares are held as a "capital
asset" within the meaning of Section 1221 of the Code.

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The J. M. Smucker Company
July 10, 2000
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                  Based upon the foregoing, we are of the opinion that:

                           (1) Holders of Class A Shares and/or Class B Shares
                  that receive solely New Common Shares in the Exchange pursuant
                  to the Merger Agreement will not recognize gain or loss; and

                           (2) Holders of Class A Shares and/or Class B Shares
                  that receive solely cash in the Exchange pursuant to the
                  Merger Agreement will recognize capital gain or loss equal to
                  the difference between the amount of cash received and the
                  shareholder's adjusted tax basis in the shares surrendered,
                  unless, in the case of a shareholder that is treated as
                  holding New Common Shares under the constructive ownership
                  rules of the Code, or otherwise, the receipt by that
                  shareholder of cash has the effect of a dividend.

                  Our opinion is based on the relevant provisions of the Code,
and on Treasury regulations, administrative interpretations, and judicial
decisions as in effect on the date of this letter. These authorities are subject
to change, which could be either prospective or retroactive, and we can provide
no assurance as to the effect that any such change may have on the opinion that
we have expressed above. We assume no obligation to inform you of any such
change.

                  This opinion is being furnished to you solely for the benefit
of the Company. We hereby consent to the filing of this opinion as Exhibit 8 to
the Registration Statement, and to the reference to our Firm under the caption
"Legal Matters" in the proxy statement-prospectus constituting part of the
Registration Statement.

                                          Very truly yours,



                                          /s/ Jones, Day, Reavis & Pogue