EXHIBIT 8.1

                                December 5, 1997

BTI Telecom Corp.
BTI Corporate Center
4300 Six Forks Road
Raleigh, North Carolina 27609

Ladies and Gentlemen:

     We have acted as counsel to BTI Telecom Corp., a North Carolina
corporation (the "Issuer"), in connection with the offer to exchange under the
Securities Act of 1933, as amended (the "Act"), of $250.0 million in principal
amount of 10-1/2% Senior Notes due 2007, registered under the Act (the "Exchange
Notes"), for any and all of its outstanding 10-1/2% Senior Notes due 2007 (the
"Initial Notes"), up to an aggregate of $250.0 million, pursuant to Registration
Statement on Form S-4, to be filed with the Securities and Exchange Commission
on or about the date hereof (the "Registration Statement").

      As such counsel, we have examined those documents that we have deemed
necessary as a basis for the opinion hereinafter expressed. Based upon the
foregoing, we are of the opinion that:

      The description under the heading "Certain U.S. Federal Income Tax
Consequences" in the Registration Statement fairly describes the material
United States federal income tax consequences to holders resulting from their
exchange of the Initial Notes for the Exchange Notes, and the ownership and
disposition of the Exchange Notes under currently applicable federal income
tax law.

      We hereby consent to the filing of the opinion as an Exhibit to the
Registration Statement, and to the reference to us under the heading "Certain
U.S. Federal Income Tax Consequences" therein.


                                              Very truly yours,
                                              WYRICK ROBBINS YATES & PONTON LLP