Exhibit 8.1

                  [LETTERHEAD OF SONNENSCHEIN NATH & ROSENTHAL]



                                                           January 30, 2002


Young Broadcasting Inc.
599 Lexington Avenue
New York, New York 10022

Ladies and Gentlemen:

         We have been requested by Young Broadcasting Inc. ("Company"), a
Delaware corporation, to furnish our opinion in connection with the registration
statement ("Registration Statement") on Form S-4, filed concurrently herewith,
with respect to the registration of $250,000,000 principal amount of 8-1/2%
Senior Notes due 2008 of the Company ("Exchange Notes") to be offered ("Exchange
Offer") in exchange for outstanding 8-1/2% Senior Notes due 2008 ("Initial
Notes").

         We have made such examination as we have deemed necessary for the
purpose of this opinion. Based upon the terms of the Exchange Offer, the Initial
Notes and the Exchange Notes, which are set forth in the Registration Statement,
it is our opinion that the summary set forth under the heading "United States
Federal Tax Considerations" in the Registration Statement accurately describes,
in all material respects, the material United States federal income tax
consequences of the Exchange Offer to the holders of the Initial Notes that may
be relevant with respect to the exchange of Initial Notes for Exchange Notes,
but does not purport to discuss all United States federal income tax
consequences that may be relevant to a particular holder of Initial Notes in
light of such holder's particular circumstances.

         The foregoing opinion is based upon current provisions of the Internal
Revenue Code of 1986, as amended, the Treasury Regulations promulgated
thereunder, published pronouncements of the Internal Revenue Service, and case
law, any of which may change at any time with retroactive effect. We undertake
no obligation to update this opinion in respect of any such changes.

         The opinion is rendered solely to you in connection with the above
matter. This opinion may not be relied upon by you for any other purposes or
relied upon or furnished to any other person without our prior written consent.


Young Broadcasting Inc.

January 30, 2002
Page 2

         We hereby consent to the use of this opinion as an exhibit to the
Registration Statement and to the reference to our name under the caption "Legal
Matters" in the prospectus included in the Registration Statement.



                                              Very truly yours,


                                              /s/ Sonnenschein Nath & Rosenthal


                                              SONNENSCHEIN NATH & ROSENTHAL