EX-8
     
                     [Carter, Ledyard & Milburn Letterhead]


                                                                  (212) 238-8809

                                    January ____, 1998


Brill Media Company, LLC
420 N.W. Fifth Street, Suite 3-B
P.O. Box 3353
Evansville, Indiana 47732

            Re:  Form S-4 Registration Statement

Ladies and Gentlemen:

      We have acted as counsel to Brill Media Company, LLC, a Virginia limited
liability company ("BMC"), and Brill Media Management, Inc., a Virginia
corporation ("Media" and collectively with BMC, the "Company"), in connection
with an exchange offer (the "Exchange Offer") under which $105,000,000 in
aggregate principal amount of the Company's Series B 12% Senior Notes due 2007
(the "Exchange Notes") and $3,000,000 in aggregate principal amount of the
Company's Series B Appreciation Notes due 2007 (the "Exchange Appreciation
Notes"), will be offered in exchange for the Company's outstanding 12% Senior
Notes due 2007 (the "Original Notes") and the Company's outstanding Appreciation
Notes (the "Original Appreciation Notes"), respectively. The Exchange Offer is
the subject of a Registration Statement on Form S-4 under the Securities Act of
1933 (the "Registration Statement").

      We have examined originals or copies, certified or otherwise identified to
our satisfaction, of all such agreements, certificates and other statements of
corporate officers and other representatives of the Company as we have deemed
necessary as a basis for this opinion. In such examination we have assumed the
genuineness of all signatures and the authenticity of all documents submitted to
us as originals and the conformity with the originals of all documents submitted
to us as copies.


Brill Media Company, LLC                                                     -2-


      Based on and subject to the foregoing, we are of the opinion that the
section entitled "Certain Federal Income Tax Considerations" in the prospectus
constituting Part I of the Registration Statement contains an accurate general
description, under currently applicable law, of the principal United States
federal income tax considerations that apply to holders of Exchange Notes and
Exchange Appreciation Notes.

      We consent to the filing of this opinion as an Exhibit to the Registration
Statement. In giving this consent we do not acknowledge that we come within the
category of persons whose consent is required by the Securities Act or the rules
and regulations promulgated thereunder.

                                          Very truly yours,


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