[GIBSON, DUNN & CRUTCHER LLP LETTERHEAD]

                                                                     Exhibit 8.2



                                February 12, 2002




                                                                      Client No.
(202) 955-8500                                                     C 04554-00005


Arguss Communications, Inc.
One Church Street
Suite 302
Rockville, Maryland 20850



Ladies and Gentlemen:

         We have acted as special counsel to Arguss Communications, Inc. a
Delaware corporation ("Target"), in connection with the proposed tender offer
(the "Offer") by Dycom Industries, Inc. a Florida corporation ("Parent"),
through Troy Acquisition Corp., a Delaware corporation and a direct,
wholly-owned subsidiary of Parent ("Merger Sub"), for the outstanding stock of
Target and the subsequent merger (the "Merger") of Merger Sub with and into
Target.


         In formulating our opinion, we have reviewed such documents as we
deemed necessary or appropriate, including (i) the Agreement and Plan of Merger,
dated January 7, 2002, among Parent, Merger Sub and Target (the "Merger
Agreement") and (ii) the Registration Statement of Parent on Form S-4 dated
January 23, 2002, as amended, (the "Registration Statement"), filed with the
United States Securities and Exchange Commission (the "Commission"), including
the prospectus of Parent that is contained therein (the "Prospectus").



         Our opinion set forth below assumes (i) the accuracy of the statements
and facts concerning the Offer and the Merger set forth in the Merger Agreement
and the Registration Statement; (ii) that the Offer and the Merger will be
consummated in the manner contemplated by, and in accordance with, the terms set
forth in the Merger Agreement and the Registration Statement including, but not
limited to, (a) that the Minimum Condition (as defined in the Merger Agreement)
is met in the Offer, and (b) that the Merger will be completed promptly
following the Offer; and (iii) that the representations made to us by Target,
which are set forth in a Certificate dated February 12, 2002, and the
representations made to us by Parent, which are set forth in a Certificate dated
February 12, 2002, are accurate and will continue to be accurate through the
effective time of the Merger.




Arguss Communications, Inc.
February 12, 2002
Page 2


         Based upon the foregoing and in reliance thereon, and subject to the
qualifications, exceptions, assumptions and limitations contained herein, we are
of the opinion that:

         1.       The Offer and the Merger will be treated for United States
                  federal income tax purposes as a reorganization within the
                  meaning of Section 368(a) of the Internal Revenue Code of
                  1986, as amended (the "Code").

         2.       Parent, Merger Sub, and Target each will be treated as a party
                  to the reorganization within the meaning of Section 368(b) of
                  the Code.

         3.       We confirm that the discussion in the Prospectus under the
                  heading "THE OFFER--Material United States Federal Income Tax
                  Consequences" to the extent it consists of statements of law
                  and legal conclusions, and subject to the assumptions,
                  limitations and conditions set forth therein, constitutes our
                  opinion as to the material United States federal income tax
                  consequences of the Offer and the Merger to the stockholders
                  of Target.

We express no opinion concerning any tax consequences of the Offer and the
Merger other than those specifically set forth herein.

         Our opinion is based on current provisions of the Code, Treasury
Regulations promulgated thereunder, published pronouncements of the Internal
Revenue Service and case law, any of which may be changed at any time with
retroactive effect. Any change in applicable law or the facts and circumstances
surrounding the Offer or the Merger, or any inaccuracy in the statements, facts,
assumptions, and representations on which we relied, may affect the continuing
validity of the opinion set forth herein. We assume no responsibility to inform
you of any such changes or inaccuracy that may occur or come to our attention.


         We consent to the use of our name under the headings " Risk Factors --
Risks Relating to the Offer and the Merger -- The receipt of Dycom shares could
be taxable to you, depending on facts surrounding the offer and the merger",
"The Offer--Material United States Federal Income Tax Consequences" and "Legal
Matters" in the Registration Statement. We consent to the filing of this opinion
with the Commission as Exhibit 8.2 to the Registration Statement. In giving
these consents, we do not thereby admit that we are within the category of
persons whose consent is required under Section 7 of the Securities Act of 1933,
as amended, or the rules and regulations of the Commission promulgated
thereunder.


                                             Very truly yours,



                                         /s/ GIBSON, DUNN & CRUTCHER LLP

ADP/DWM/BHR