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                                                                       Exhibit 8

                                                                   June 30, 1997

Huntington Bancshares Incorporated
41 South High Street
Columbus, Ohio  43287

Ladies and Gentlemen:

         As special tax counsel to Huntington Capital I (the "Trust") and
Huntington Bancshares Incorporated in connection with the exchange offer by the
Trust of $200,000,000 of its Floating Rate Capital Securities pursuant to a
preliminary Prospectus dated June 30, 1997 (the "Prospectus"), and assuming that
the operative documents described in the Prospectus will be performed in
accordance with the terms described therein, we hereby confirm to you our
opinion as set forth under the heading "Certain United States Federal Income Tax
Consequences" in the Prospectus, subject to the limitations set forth therein.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the references to us under the hearing "Certain
United States Federal Income Tax Consequences" in the Prospectus. 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 Act.

                                            Very truly yours,

                                            /s/ Porter, Wright, Morris & Arthur

                                            PORTER, WRIGHT, MORRIS & ARTHUR