EXHIBIT (8)

Haskell Slaughter & Young, L.L.C.
1200 AmSouth/Harbert Plaza
1901 Sixth Avenue North
Birmingham, Alabama  35203

                                                                   July 18, 1996


HEALTHSOUTH Corporation
Two Perimeter Park South
Birmingham, Alabama 35243

Gentlemen:

         You have  requested our opinion  regarding  the  discussion of material
federal income tax consequences under the captions "SUMMARY OF PROSPECTUS--PROXY
STATEMENT-The Merger -- Certain Federal Income Tax Consequences" and "THE MERGER
- -- Certain Federal Income Tax  Consequences" in the  Prospectus-Proxy  Statement
(the  "Prospectus-Proxy  Statement")  which will be included in the Registration
Statement on Form S-4 (the  "Registration  Statement")  filed on the date hereof
with the  Securities  and  Exchange  Commission  (the  "Commission")  under  the
Securities Act of 1933, as amended (the "Securities Act"). The  Prospectus-Proxy
Statement relates to the proposed merger of Empire  Acquisition  Corporation,  a
wholly-owned subsidiary of HEALTHSOUTH  Corporation,  with and into Professional
Sports Care  Management,  Inc. This opinion is delivered in accordance  with the
requirement of Item 601(b)(8) of Regulation S-K under the Securities Act.

         In  rendering  our  opinion,  we  have  reviewed  the  Prospectus-Proxy
Statement and such other materials as we have deemed necessary or appropriate as
a  basis  for our  opinion.  In  addition,  we have  considered  the  applicable
provisions  of  the  Internal  Revenue  Code  of  1986,  as  amended,   Treasury
regulations,  pertinent  judicial  authorities,  rulings of the Internal Revenue
Service and such other authorities as we have considered relevant.

         Based upon the foregoing,  it is our opinion that the  statements  made
under the captions "SUMMARY OF PROSPECTUS-PROXY  STATEMENT-The Merger -- Certain
Federal Income Tax  Consequences"  and "THE MERGER -- Certain Federal Income Tax
Consequences"  in the  Prospectus-Proxy  Statement,  to  the  extent  that  they
constitute summaries or descriptions of matters of law or legal conclusions, are
correct  in all  material  respects.  There can be no  assurance  that  contrary
positions may not be asserted by the Internal Revenue Service.

         This opinion is being furnished in connection with the Prospectus-Proxy
Statement.  You  may  rely  upon  and  refer  to the  foregoing  opinion  in the
Prospectus-Proxy  Statement. Any variation or difference in the facts from those
set forth or assumed  either  herein or in the  Prospectus-Proxy  Statement  may
affect the conclusions stated herein.


         In accordance  with the  requirements  of Item 601(b)(23) of Regulation
S-K under the Securities Act, we hereby consent to the use of our name under the
caption  "THE  MERGER  --  Certain  Federal  Income  Tax  Consequences"  in  the
Prospectus-Proxy  Statement  and to the filing of this  opinion as an Exhibit to
the Registration Statement.


                                          Very truly yours,

                                          HASKELL SLAUGHTER & YOUNG, L.L.C.


                                          By  /s/ Ross N. Cohen
                                              -----------------------------
                                              Ross N. Cohen