Exhibit 8.1

                   [Letterhead of Morgan, Lewis & Bockius LLP]


June 12, 2003

AmeriGas Partners, L.P.
460 North Gulph Road
King of Prussia, PA 19406

Ladies and Gentlemen:

We have acted as counsel to AmeriGas Partners, L.P. (the "Partnership") in
connection with the Partnership's offering (the "Offering") of common units
representing limited partnership interests ("Common Units") in the Partnership
pursuant to the Partnership's registration statements on Form S-3 (registration
numbers 333-73686 and 333-45902, collectively, the "Registration Statement"). In
connection therewith, we reviewed the discussion set forth under the caption
"Tax Considerations" in the Registration Statement, as supplemented by the
discussion set forth under the caption "Recent Tax Developments" in the
prospectus supplement (the "Prospectus Supplement"), filed with the Securities
and Exchange Commission on June 12, 2003 pursuant to Rule 424(b) under the
Securities Act of 1933 (the "Discussion").

The Discussion, subject to the qualifications and assumptions stated in the
Discussion, insofar as the Discussion refers to matters of federal income tax
law and legal conclusions with respect to those matters, and the limitations and
qualifications set forth herein, constitutes our opinion as to the material
United States federal income tax consequences for purchasers of the Common Units
pursuant to the Offering.

This opinion letter is limited to the matters set forth herein, and no opinions
are intended to be implied or may be inferred beyond those expressly stated
herein. Our opinion is rendered as of the date hereof and we assume no
obligation to update or supplement this opinion or any matter related to this
opinion to reflect any change of fact, circumstances, or law after the date
hereof. In addition, our opinion is based on the assumption that the matter will
be properly presented to the applicable court. Furthermore, our opinion is not
binding on the Internal Revenue Service or a court. In addition, we must note
that our opinion represents merely our best legal judgment on the matters
presented and that others may disagree with our conclusion. There can be no
assurance that the Internal Revenue Service will not take a contrary position or
that a court would agree with our opinion if litigated.



Amerigas Partners, LP
June 11, 2003
Page 2

We hereby consent to the filing of this opinion as an exhibit to a Current
Report on Form 8-K of the Partnership, the incorporation by reference of this
opinion in the Registration Statement and the references to our firm and this
opinion contained in the Prospectus Supplement forming a part of the
Registration Statement. In giving this consent, however, we do not hereby admit
that we are within the category of persons whose consent is required under
Section 7 of the Act, or the rules and regulations of the Securities and
Exchange Commission thereunder.

Very truly yours,

/s/ Morgan, Lewis & Bockius LLP


Morgan, Lewis & Bockius LLP