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                                                                     EXHIBIT 8.1


                       BLACKWELL SANDERS PEPER MARTIN LLP
              2300 MAIN STREET, SUITE 1000, KANSAS CITY, MO 64108
                  P.O. BOX 419777, KANSAS CITY, MO 64141-6777
                    TEL: (816) 983-8000 FAX: (816) 983-8080
                            WEBSITE: www.bspmlaw.com

                                 July 18, 2000

BVBC Capital Trust I
Blue Valley Ban Corp
11935 Riley
Overland Park, Kansas 66225-6128

Ladies and Gentlemen:

         We have acted as counsel to Blue Valley Ban Corp (the "Company") and to
BVBC Capital Trust I (the "Trust") in connection with the registration statement
of the Company and the Trust on Form S-1 (the "Registration Statement"), of
which a prospectus ("Prospectus") is a part, filed by the Company and the Trust
with the United States Securities and Exchange Commission under the Securities
Act of 1933, as amended. This opinion is furnished pursuant to the requirements
of Item 601(b)(8) of Regulation S-K.

         For the purposes of rendering this opinion, we have reviewed and
relied upon the Registration Statement and such other documents and instruments
as we deemed necessary for the rendering of this opinion. In our examination of
relevant documents, we have assumed the genuineness of all signatures, the
authenticity of all documents submitted to us as originals, the conformity to
original documents to all documents submitted to us as copies, the authenticity
of such copies and the accuracy and completeness of all corporate records made
available to us by the Company and the Trust.

         Based solely upon our review of such documents, and upon such
information as the Company has provided to us (which we have not attempted to
verify in any respect), and reliance upon such documents and information, we
hereby adopt as our opinion the statements contained in the Prospectus under the
caption "Material Federal Income Tax Consequences," insofar as such statements
constitute matters of law or legal conclusions.

         Our opinion is limited to the federal income tax matters described
above and does not address any other federal income tax considerations or any
state, local, foreign, or other tax considerations. If any of the information on
which we have relied is incorrect, or if changes in the relevant facts occur
after the date hereof, our opinion could be affected thereby.

         Moreover, our opinion is based on the Internal Revenue Code of 1986,
as amended, applicable Treasury regulations promulgated thereunder, and Internal
Revenue Service rulings, procedures, and other pronouncements published by
the United States Internal Revenue Service. These authorities are all subject
to change, and such change may be made with retroactive effect. We can give
no assurance that, after such change, our opinion would not be different.
We undertake no responsibility to update or supplement our opinion. This opinion
is not binding on the Internal Revenue Service, and there can be no assurance,
and none is hereby given, that the Internal Revenue Service will not take a
position contrary to one or more of the positions reflected in the foregoing
opinion, or that our opinion will be upheld by the courts if challenged by the
Internal Revenue Service.

         We hereby consent to the filing of this opinion as an exhibit to
the Registration Statement. We also consent to the use of our name in the
Prospectus under the caption "Material Federal Income Tax Consequences."

                                         Very truly yours,


                                         /s/ Blackwell Sanders Peper Martin LLP