Exhibit 8.1


(202) 274-2000

April 28, 2004

Boards of Directors
Atlantic Coast Federal
Atlantic Coast Federal, MHC
Atlantic Coast Federal Corporation
505 Haines Avenue
Waycross, Georgia 31501

Ladies and Gentlemen:

     You have requested this firm's opinion regarding certain federal income tax
consequences which will result from a stock offering (the "Offering") of the
shares of common stock of Atlantic Coast Federal Corporation, a federal mid-tier
holding company (the "Company") and the wholly owned subsidiary of Atlantic
Coast Federal, MHC, a federal mutual holding company (the "Mutual Holding
Company"). The Company owns all of the outstanding common stock of Atlantic
Coast Federal, a federally chartered stock savings association (the
"Association").

     In connection therewith, we have made such investigations as we have deemed
relevant or necessary for the purpose of this opinion. In our examination, we
have assumed the authenticity of original documents, the accuracy of copies and
the genuineness of signatures. We have further assumed the absence of adverse
facts not apparent from the face of the instruments and documents we examined
and have relied upon the accuracy of the factual matters set forth in the Plan
of Stock Issuance of Atlantic Coast Federal Corporation (the "Plan") and the
Registration Statement filed on Form S-1 by the Company with the Securities and
Exchange Commission ("SEC") under the Securities Act of 1933.

     Our opinion is based upon the existing provisions of the Internal Revenue
Code of 1986, as amended (the "Code"), and regulations thereunder (the "Treasury
Regulations"), and upon current Internal Revenue Service ("IRS") published
rulings and existing court decisions, any of which could be changed at any time.
Any such changes may be retroactive and could significantly modify the
statements and opinions expressed herein. Similarly, any change in the facts and
assumptions stated below, upon which this opinion is based, could modify the
conclusions. This opinion is as of the date hereof, and we disclaim any
obligation to advise you of any change in any matter considered herein after the
date hereof.

     We, of course, opine only as to the matters we expressly set forth, and no
opinions should be inferred as to any other matters or as to the tax treatment
of the transactions that we do not specifically address. We express no opinion
as to other federal laws and regulations, or as to


Boards of Directors
Atlantic Coast Federal
Atlantic Coast Federal, MHC
Atlantic Coast Federal Corporation
April 28, 2004
Page 2


laws and regulations of other jurisdictions, or as to factual or legal matters
other than as set forth herein.

     For purposes of this opinion, we rely on the representations as to certain
factual matters provided to us by the Company, as set forth in the affidavit of
its authorized officer. Capitalized terms used but not defined herein shall have
the same meaning as set forth in the Plan.

Description of Proposed Transactions

     Based solely upon our review of the documents described above, and in
reliance upon such documents, we understand that the relevant facts are as
follows:

     On January 1, 2003, pursuant to a Plan of Mutual Holding Company
Reorganization, the Association reorganized from a federally chartered mutual
savings and loan association into the mutual holding company structure (the
"Reorganization"). As part of the Reorganization, the Association became a
federally chartered stock savings and loan association wholly owned by the
Company. Simultaneously, the Company became wholly owned by the Mutual Holding
Company.

     On March 12, 2004, the Boards of Directors of the Association, the Company
and the Mutual Holding Company adopted the Plan which provides for the offer and
sale of up to 49.9% of the shares of the Company's Common Stock. In adopting the
Plan, the Board of Directors has determined that the Offering is advisable and
in the best interest of the Association, the Company, the Mutual Holding Company
and its members. Pursuant to the Plan, the Company is offering between 4,080,000
and 5,520,000 shares of Common Stock (with the ability to increase the Offering
to 6,348,000 shares) which represents approximately 40% of the shares of the
Common Stock of the Company that will be outstanding at the conclusion of the
Offering. The shares of Company Common Stock are being offered, in the
respective priorities set forth in the Plan, to eligible account holders
("Eligible Account Holders"), the Association's tax-qualified employee plans
(the "Employee Plans"), supplemental eligible account holders ("Supplemental
Eligible Account Holders"), and, to the extent shares remain available, members
of the public in a community offering ("Direct Community Offering") or a
syndicated community offering ("Syndicated Community Offering"), or a
combination thereof. All shares of Common Stock sold in the Offering will be
issued from authorized but unissued shares of the Company. The Offering will
have no impact on depositors, borrowers or other customers of the Association.

Opinions

     Based on the foregoing description of the Offering, and subject to the
qualifications and limitations set forth in this letter, we are of the opinion
that:


Boards of Directors
Atlantic Coast Federal
Atlantic Coast Federal, MHC
Atlantic Coast Federal Corporation
April 28, 2004
Page 3


     1. No gain or loss will be recognized by Company on the receipt of money in
exchange for the issuance of shares of Company Common Stock sold in the
Offering. Section 1032 of the Code.

     2. It is more likely than not that the fair market value of the
non-transferable subscription rights to purchase Company Common Stock will be
zero. Accordingly, no gain or loss will be recognized by Eligible Account
Holders or Supplemental Eligible Account Holders upon the distribution to them
of the nontransferable subscription rights to purchase Company Common Stock. No
taxable income will be realized by the Eligible Account Holders or Supplemental
Eligible Account Holders or other eligible subscribers as a result of the
exercise of the nontransferable subscription rights. Rev. Rul. 56-572, 1956-2
C.B. 182.

     3. It is more likely than not that the basis of the Company Common Stock to
persons who purchase in the Offering will be the purchase price thereof. Section
1012 of the Code. The holding period of a stockholder who purchases shares in
the Offering will commence upon the consummation of the sale of such Common
Stock to such stockholder pursuant to the exercise of the subscription rights.
Section 1223(6) of the Code.

     Our opinion under 2 above is predicated on the representation that no
person shall receive any payment, whether in money or property, in lieu of the
issuance of subscription rights. Our opinions under 2 and 3 are based on the
assumption that nontransferable subscription rights do not have any economic
value at the time of distribution or the time the subscription rights are
exercised. In this regard, we note that the subscription rights will be granted
at no cost to the recipients, will be legally non-transferable and of short
duration, and will provide the recipient with the right only to purchase shares
of common stock at the same price to be paid by the general public in the
Offering. We also note that the Internal Revenue Service has not in the past
concluded that the subscription rights have value. Based on the foregoing, we
believe that it is more likely than not that the nontransferable subscription
rights to purchase common stock have no value. However, the issue of whether or
not the subscription rights have value is based on all the facts and
circumstances. If the nontransferable subscription rights are subsequently found
to have an ascertainable value greater than zero, income may be recognized by
various recipients of the nontransferable subscription rights (in certain cases,
whether or not the rights are exercised) and the Company could recognize gain on
the distribution of the nontransferable subscription rights. Unlike private
rulings, an opinion of Luse Gorman Pomerenk & Schick, P.C., is not binding on
the Internal Revenue Service and the Internal Revenue Service could disagree
with the conclusions reached herein.

     We hereby consent to the filing of the opinion as an exhibit to Atlantic
Coast Federal's Form MHC-2 Application for Approval of a Minority Stock Issuance
by a Subsidiary of MHC as


Boards of Directors
Atlantic Coast Federal
Atlantic Coast Federal, MHC
Atlantic Coast Federal Corporation
April 28, 2004
Page 4


filed with the OTS and Atlantic Coast Federal Corporation's Registration
Statement on Form S-1 as filed with the SEC. We also consent to the references
to our firm in the Prospectus contained in the Form MHC-2, and S-1 under the
captions "The Stock Offering - Tax Effects of the Stock Offering" and "Legal and
Tax Matters," and to the summarization of our opinion in such Prospectus.

                                        Very truly yours,

                                        LUSE GORMAN POMERENK & SCHICK,
                                        A PROFESSIONAL CORPORATION



                                        By: /s/ Luse Gorman Pomerenk & Schick
                                            ---------------------------------