EXHIBIT 8.2

                 Form of Tax Opinion of Vinson & Elkins L.L.P.


                               ____________, 2002

Dal-Tile International Inc.
7834 Hawn Freeway
Dallas, Texas  75217

Gentlemen:

         We participated in the preparation of Registration Statement No.
___________ on Form S-4 originally filed with the Securities and Exchange
Commission by Mohawk Industries, Inc. ("Mohawk") on December 7, 2001 (as amended
from time to time and together with exhibits thereto, the "Registration
Statement"), in connection with the planned merger of Dal-Tile International
Inc. ("Dal-Tile") and Maverick Merger Sub, Inc.("Sub"), a wholly owned
subsidiary of Mohawk, pursuant to the Agreement and Plan of Merger, dated
November 19, 2001, by and among Mohawk, Sub and Dal-Tile (the "Merger
Agreement"), including the discussion set forth in the Registration Statement
under the heading "Material Federal Income Tax Consequences of the Merger." The
discussion and the legal conclusions with respect to United States federal
income tax matters set forth therein reflect our opinion, and we believe they
are accurate and complete in all material respects.

         Our opinion is based and conditioned upon the initial and continuing
accuracy of the statements, covenants, representations and assumptions set forth
in (i) the Merger Agreement, (ii) the Registration Statement, and (iii) the tax
certificates delivered to us by Mohawk and Dal-Tile. Any inaccuracies in any of
the aforementioned statements, representations, or assumptions or breach or
failure of any of the aforementioned covenants could adversely affect our
opinion. Our opinion is also based upon provisions of the United States Internal
Revenue Code of 1986, as amended, regulations promulgated or proposed thereunder
and interpretations thereof by the Internal Revenue Service and the courts, all
as of the date hereof, all of which are subject to change with prospective or
retroactive effect, and our opinion could be adversely affected or rendered
obsolete by any such change.

         We hereby consent to the use of our name in the Registration Statement
and to the filing of this opinion as part of the Registration Statement. In
giving this consent, we do not hereby admit that we are within the category of
persons whose consent is required under Section 7 of the Securities Act of 1933
and the rules and regulations of the Securities and Exchange Commission.


                                        Very truly yours,