EXHIBIT 8.1

                                 August 29, 1997



Sinclair Broadcast Group, Inc.
2000 West 41st Street
Baltimore, Maryland 21211

Dear Ladies and Gentlemen:

         We  have  acted  as tax  counsel  to  Sinclair  Broadcast  Group,  Inc.
("Sinclair")  in connection  with the preparation and filing with the Securities
and Exchange  Commission (the "Commission") of a Registration  Statement on Form
S-4 (the "Registration Statement") under the Securities Act of 1933, as amended,
for the  registration  of the 9%  Senior  Subordinated  Notes due 2007 (the "New
Notes"),  which  are  to be  offered  in  exchange  for  outstanding  9%  Senior
Subordinated  Notes  due 2007  (the  "Old  Notes").  All  capitalized  terms not
otherwise  defined  herein shall have the meaning  ascribed to such terms in the
Prospectus which forms a part of the Registration Statement.

         We have examined such documents as we have deemed relevant for purposes
of the opinion set forth herein.  In our examination of such documents,  we have
assumed,  without independent  inquiry,  the genuineness of all signatures,  the
proper execution of all documents,  the authenticity of all documents  submitted
to us as originals, the conformity to originals of all documents submitted to us
as copies,  the authenticity of the originals of any such copies,  and the legal
capacity of all natural persons.

         Based on and  subject  to the  foregoing,  it is our  opinion  that the
discussion set forth in the Prospectus under the heading "Certain Federal Income
Tax Consequences"  constitutes,  in all material  respects,  a fair and accurate
summary of the United States federal income tax consequences of the acquisition,
ownership, and disposition of the New Notes under current law.






Sinclair Broadcast Group, Inc.
August 29, 1997
Page 2



         The foregoing  opinion is based on relevant  provisions of the Internal
Revenue Code of 1986, as amended,  the Treasury  Regulations  issued thereunder,
court decisions,  and administrative  determinations as currently in effect, all
of which are subject to change, prospectively or retroactively,  at any time. We
undertake  no  obligation  to update or  supplement  this opinion to reflect any
changes in laws that may occur after the date hereof.

         This opinion has been prepared  solely for your use in connection  with
the filing of the Registration Statement and should not be quoted in whole or in
part or otherwise  be referred  to, nor  otherwise be filed with or furnished to
any  governmental  agency or other person or entity,  without our express  prior
written consent.

         We hereby  consent to the  filing of this  opinion as an exhibit to the
Registration  Statement  and to the use of our name  therein  under the  heading
"Legal Matters" in the Prospectus.

                                Very Truly Yours,

                                WILMER, CUTLER & PICKERING



                                By: /s/ Terrill A. Hyde
                                    ----------------------------------------
                                    Terrill A. Hyde
                                    A Partner