Exhibit 8


                              Dewey Ballantine LLP
                          1301 Avenue of the Americas
                           New York, New York  10019


                                                                  April 12, 2001

Duke Energy Corporation
526 South Church Street
Charlotte, North Carolina  28202

          Re:  Registration Statement on Form S-3

Gentlemen:

          We have acted as counsel to Duke Energy Corporation ("Duke"), Duke
Energy Capital Trust III, Duke Energy Capital Trust IV and Duke Energy Capital
Trust V (the "Trusts") in connection with the preparation of a Registration
Statement on Form S-3, including a preliminary prospectus and preliminary
prospectus supplement, being filed today with the Securities and Exchange
Commission (the "Commission") for the registration under the Securities Act of
1933 (the "Securities Act"), of, among other securities, (1) Junior
Subordinated Notes (the "Junior Subordinated Notes") to be issued by Duke to the
Trusts, (2) Trust Preferred Securities (liquidation amount $       per Preferred
Security) to be issued by the Trusts and (3) Duke's Guarantees (as defined in
the Registration Statement) with respect to such Trust Preferred Securities. The
Trusts will be organized pursuant to an amended and restated trust agreement
between Duke and the trustees named therein. The Junior Subordinated Notes will
be issued pursuant to the Subordinated Indenture, as supplemented, dated as of
December 1, 1997, between Duke and the trustee named therein and the Guarantees
will be issued pursuant to guarantee agreements between Duke and the trustee
named therein, in the form filed as an exhibit to the Registration Statement.

          On the basis and subject to the accuracy of the statements contained
in the materials referred to above, and our consideration of such other matters
as we have deemed necessary, it is our opinion that under current law the
material federal income tax consequences to holders of Trust Preferred
Securities issued by the Trusts will be as described under the heading "Material
Federal Income Tax Considerations" in the preliminary prospectus supplement
constituting part of the Registration Statement.  You have not requested, and we
do not express, an opinion concerning any other tax consequences of the issuance
by the Trusts of the Trust Preferred Securities.  This opinion is not to be
used, circulated, quoted or otherwise referred to for any purpose without our
express written permission.

          We hereby consent to the filing of this opinion with the Commission as
an exhibit to the Registration Statement and to the statements with respect to
our firm in the section captioned "Material Federal Income Tax Considerations"
in the preliminary prospectus


supplement constituting part of the Registration Statement. In giving the
foregoing consent, we do not thereby admit, and we hereby expressly disclaim,
that we come within the category of persons whose consent is required under
Section 7 of the Securities Act or the rules and regulations of the Commission
thereunder.

                                    Very truly yours,

                                    /s/ Dewey Ballantine LLP



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