Exhibit 8.2

                             MOORE & VAN ALLEN, PLLC
                                ATTORNEYS AT LAW
                        100 NORTH TRYON STREET, FLOOR 47
                            CHARLOTTE, NC 28280-4003
                            TELEPHONE (704) 331-1000
                             TELEFAX (704) 331-1159













                                  June 5, 1996




First Union Residential Securitization Transactions, Inc.
One First Union Center
Charlotte, North Carolina  28288-0600

Ladies and Gentlemen:

         We have advised First Union  Residential  Securitization  Transactions,
Inc. (the  "Registrant")  with respect to certain  federal income tax aspects of
the issuance by the  Registrant  of certain  Residential  Mortgage  Pass-Through
Certificates  (the  "Certificates").  Such advice conforms to the description of
selected  federal income tax  consequences to holders of the  Certificates  that
appears  under the heading  "Certain  Federal  Income Tax  Consequences"  in the
prospectus (the  "Prospectus")  forming a part of the Registration  Statement on
Form S-3  ("Registration  Statement")  as prepared for filing by the  Registrant
with the Securities and Exchange  Commission (the  "Commission")  under Rule 415
promulgated  under the  Securities  Act of 1933,  as amended  (the  "Act"),  for
registration  of the  Certificates  under  the Act.  Such  description  does not
purport  to  discuss  all  possible  income tax  ramifications  of the  proposed
issuance, but with respect to those tax consequences which are discussed, in our
opinion the description is accurate in all material respects.

         We hereby  consent to the  filing of this  opinion as an exhibit to the
Registration  Statement  and to the use of our name  wherever  appearing  in the
Registration  Statement and the  Prospectus.  In giving such consent,  we do not
consider  that we are  "experts,"  within the meaning of the term as used in the
Act or the rules and  regulations  of the  Commission  issued  thereunder,  with
respect to any part of the Registration Statement,  including this opinion as an
exhibit or otherwise.

                                           Very truly yours,

                                           MOORE & VAN ALLEN, PLLC

                                           /s/ MOORE & VAN ALLEN, PLLC