EXHIBIT 8
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                                   LAW OFFICES
                                 MALONEY & KNOX
                       5225 Wisconsin Ave., NW, Suite 316
                           Washington, D.C. 20015-2014
                        (202) 293-1414 (202) 293-1702 fax

                                  April 8, 1998

Board of Directors
American Bancorporation
1025 Main Street, Suite 800
Wheeling, WV 26003

                           Re:  Registration Statement on Form S-2

Dear Board Members:

         As special  federal tax counsel to  American  Bancorporation  Financial
Capital Trust I (the "Issuer") and American  Bancorporation  in connection  with
the  issuance  by  the  Issuer  of up to  $12,650,000  of its  Cumulative  Trust
Preferred Securities pursuant to the prospectus (the "Prospectus")  contained in
the Registration  Statement,  and assuming 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
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 heading  "Certain
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,

                                                     MALONEY & KNOX

                                                     By: /s/ Barry C. Maloney
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                                                             Barry C. Maloney