Exhibit 8.1


                                [D&W Letterhead]

                               [________ ___], 2003

The Frontier Fund
c/o Equinox Fund Management, LLC
1660 Lincoln Street, Suite 100
Denver, Colorado 80264

         Re:  The Frontier Fund Tax Opinion

Ladies and Gentlemen:

         We have acted as your counsel in connection with the preparation of the
Registration Statement on Form S-1 (the "Registration Statement") filed on or
about [August ___], 2003, with the Securities and Exchange Commission under the
Securities Act of 1933, as amended, relating to Units of The Frontier Fund,
which was formed as a Delaware statutory trust on August 8, 2003 (the "Trust").

         We have reviewed: (i) the Declaration of Trust and Trust Agreement
dated as of August 8, 2003, by and among Equinox Fund Management, LLC, a
Delaware limited liability company (the "Managing Owner"), Wilmington Trust
Company and the Unit Holders from time to time thereunder (the "Trust
Agreement"); (ii) the Registration Statement and the Prospectus constituting
part of the Registration Statement (the "Prospectus"); (iii) the exhibits to the
Registration Statement; and (iv) such other data and documents as we have deemed
necessary or appropriate as a basis for the opinions set forth below. In
addition, we have reviewed such questions of law as we have considered necessary
and appropriate. In rendering these opinions, we have relied upon, without
independent investigation or verification, the representations set forth in the
Certificate of even date herewith delivered to us by the Managing Owner of the
Trust (the "Certificate"), and the facts and information set forth in the
documents referred to above. Capitalized terms used herein and not otherwise
defined are as defined in the Prospectus.

         Our opinions with respect to federal income tax matters are based upon
the existing provisions of the Internal Revenue Code of 1986, as amended (the
"Code"), currently applicable Treasury Department regulations issued thereunder,
current published administrative positions of the Internal Revenue Service
contained in revenue rulings and revenue procedures and judicial decisions. All
of the foregoing authorities are subject to change, which may be retroactive,
and to possibly differing interpretations. Any change in these authorities may
affect the opinions rendered herein.

         An opinion of counsel is predicated on all the facts, conditions and
assumptions set forth in the opinion and is based upon counsel's analysis of the
statutes, regulatory interpretations and case law in effect as of the date of
the opinion. It is not a guarantee of the current status of the law and should
not be accepted as a guarantee that a court of law or an administrative agency
will concur in the opinion.



The Frontier Fund
[August ___], 2003
Page 2


         Based upon the foregoing, we hereby confirm our opinion expressed under
the caption "Federal Income Tax Consequences" in the Prospectus that the Trust
will be treated as a partnership for federal income tax purposes and, assuming
that at least 90% of the gross income of the Trust will constitute "qualifying
income" within the meaning of Section 7704(d) of the Code, the Trust will not be
a publicly traded partnership treated as a corporation.

         In addition, based upon the foregoing, we hereby confirm that the
discussion set forth under the caption "Federal Income Tax Consequences" in the
Prospectus constitutes our opinion and correctly summarizes the material federal
income tax consequences as of the date of the Prospectus to an individual who is
a United States citizen or resident of the purchase, ownership and disposition
of Units in the Trust.


         We express no opinion regarding any matter other than the federal
income tax matters explicitly addressed herein.

         We hereby consent to the filing of this opinion as an Exhibit to the
Registration Statement and all references to our firm included in or made a part
of the Registration Statement. 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 or the rules and regulations of the Commission thereunder.

                                              Very Truly Yours,



FFH/KAS