Exhibit 8.1

                                A. Timothy Scott
          Senior Vice President and Tax Counsel of Public Storage, Inc.
                      701 Western Ave. . Glendale, CA 91201
                           (818) 244-8080 x286 (voice)
                              (818) 548-9288 (fax)


                                  June 26, 2002


PS Partners VI, Ltd.,
A California Limited Partnership
701 Western Avenue
Glendale, California  91201

                       Re: Merger Transaction Tax Opinion

Ladies & Gentlemen:


          As Senior Vice President and Tax Counsel of Public Storage, Inc.
("PSI"), I have examined amendment no. 1 to the registration statement on Form
S-4 expected to be filed by PSI with the Securities and Exchange Commission on
or about the date of this opinion (the "Registration Statement"). Unless
otherwise defined in this opinion letter, capitalized terms used below have the
same meaning as set forth in the Registration Statement. The Registration
Statement serves as the definitive information statement relating to PSI's
acquisition of the interests held by the public limited partners of PS Partners
VI, Ltd., a California Limited Partnership ("Partners VI"), pursuant to a
proposed merger of PS Partners VI Merger Co., Inc. ("Merger Sub," which is a
second tier subsidiary of PSI) with and into Partners VI (the "Merger"). In the
Merger, each Partners VI partnership unit (other than the partnership units held
by PSI and its subsidiaries) will be converted into the right to receive PSI
common stock with a value of $546, or at the election of a limited partner, the
same amount in cash. PSI is a general partner of Partners VI and now owns
indirectly approximately 63% of the outstanding limited partnership interests in
Partners VI.


          In connection with your participation in the Merger, you have
requested my opinion that: (1) the discussion in the Registration Statement
under the heading "Federal Income Tax Considerations" describes the material
federal income tax considerations to the public limited partners as a result of
the merger and as a result of the subsequent ownership of PSI common stock for
limited partners that do not make a cash election, and (2) PSI has been
organized and operated so as to meet the requirements for qualification as a
real estate investment trust ("REIT") as defined in Sections 856 to 860 of the
Internal Revenue Code of 1986, as amended (the "Code") for each of its three
most recently completed fiscal years (1999, 2000 and 2001) and that its
organization and proposed method of operation should enable it to continue to
meet those requirements.





PS Partners VI, Ltd.,
701 Western Avenue
Glendale, California 91201
Page 2

          In preparing this opinion, I examined such documents as I considered
necessary or appropriate for purposes of issuing this opinion, including the
Registration Statement (including related appendices and exhibits, such as the
Agreement and Plan of Reorganization dated as of April 12, 2002 between PSI,
Merger Sub, and Partners VI); and PSI's Restated Articles of Incorporation.

          I also relied upon certain representations, including representations
set forth in a certificate of an officer of PSI regarding the assets, operations
and activities of PSI in the past and as to the contemplated assets, operations
and activities of PSI in the future. I have assumed that each representation and
all other information that I reviewed is true and correct in all material
respects and will remain true and correct, that representations or statements
made to the knowledge of any person are correct without that or any similar
qualification, that all obligations imposed by any documents on the parties have
been or will be performed, and that the Registration Statement and the other
information fairly describes the past and expected future actions of the parties
as relevant to this opinion. I have not made an independent investigation of the
accuracy or completeness of those matters. For example, I have not undertaken to
review and determine whether each limited partnership or limited liability
company in which PSI owns an interest properly has been classified as a
"partnership" for federal income tax purposes. Instead, I have relied upon
representations as to the status of these entities for federal income tax
purposes. If any one or more of these entities were to be classified as an
association taxable as a corporation for federal income tax purposes, that might
preclude PSI from qualifying as a REIT for federal income tax purposes and
therefore could have a material adverse impact on this opinion.

          Based on the facts and representations and subject to the assumptions,
qualifications and limitations referred to in this letter and in the
Registration Statement, I am of the opinion that:

          (1) the discussion in the Registration Statement under the heading
     "Federal Income Tax Considerations" describes the material federal income
     tax considerations to the public limited partners as a result of the merger
     and as a result of the subsequent ownership of PSI common stock for limited
     partners that do not make a cash election, and

          (2) PSI has been organized and operated so as to meet the requirements
     for qualification as a REIT as defined in Code Sections 856 to 860 for each
     of its three most recently completed fiscal years (1999, 2000 and 2001) and
     its organization and proposed method of operation should enable it to
     continue to meet those requirements.





PS Partners VI, Ltd.,
701 Western Avenue
Glendale, California 91201
Page 3


          PSI's qualification and taxation as a REIT depends upon both PSI's
satisfaction in the past, and PSI's ability to meet on a continuing basis in the
future, through actual annual operating and other results, the various
requirements under the Code with regard to, among other things, the sources of
its gross income, the composition of its assets, the levels of distributions to
shareholders, the diversity of its stock ownership, and the lack of C
corporation earnings and profits. I have relied upon factual representations
with respect to these matters, including representations relating to certain
entities that are owned by or have been acquired by PSI. I did not directly
investigate the underlying facts, or otherwise review or audit the
representations made concerning PSI's compliance with the applicable
requirements, nor will I review PSI's compliance with those requirements on
continuing basis. Accordingly, due to the importance of the underlying factual
matters, including the actual results of operations, the sources of income, the
nature of assets, the level of distributions to shareholders, the diversity of
share ownership, and the absence of any C corporation earnings and profits, no
assurance can be given that PSI has satisfied or will satisfy the requirements
under the Code for qualification and taxation as a REIT for any given taxable
year.


          This opinion is based on my interpretation of the federal income tax
laws of the United States of America as they exist on the date of this letter
and does not cover any state, local or foreign tax issues. I express no opinion
regarding any tax or other issues except as is specifically set forth above. The
federal income tax laws, the regulations, and the judicial and administrative
interpretation and application of those laws is subject to change at any time.
Some issues under existing law that could significantly affect this opinion have
not been authoritatively addressed by the IRS or the courts. Of course, any
developments or changes in the law, including those reflected in future
regulations, court decisions or administrative pronouncements, may affect the
conclusions set forth in this letter, perhaps on a retroactive basis. This
opinion is also expressly conditioned upon the truth and accuracy of the
representations, warranties, assumptions, and facts upon which I have relied in
issuing this opinion.

          This opinion represents my legal judgment as to the matters set forth
above. An opinion of counsel does not have any binding effect and is not a
guarantee that the IRS will agree with the assumptions, analysis, or conclusions
of counsel. Neither PSI nor Partners VI has requested or will request any ruling
from the IRS about any issues presented by the Merger. The IRS may assert
contrary positions, and a court may sustain such a contrary position if asserted
by the IRS.


          This opinion has been prepared for your use in connection with your
participation in the Merger and the related filing of the Registration
Statement. I disclaim








any obligation to advise you of any change of law that occurs, or any facts of
which I become aware, after the date of this opinion.


          I consent to the reference to me under the caption "Legal Opinions" in
the Registration Statement and to the filing of this opinion as an exhibit to
the Registration Statement or amendments to the Registration Statement. In
giving this consent, however, I do not admit that I am an "expert" within the
meaning of the Securities Act of 1933, as amended.

                                Very truly yours,

                              /s/ A. Timothy Scott

                                 A. Timothy Scott