OPINION OF KUTAK ROCK LLP AS TO TAX MATTERS

EXHIBIT 8.1


LEGAL OPINION OF KUTAK ROCK LLP AS TO
CERTAIN TAX MATTERS


KUTAK ROCK LLP

THE OMAHA BUILDING ATLANTA
1650 FARNAM STREET DENVER
CHICAGO
OMAHA, NEBRASKA 68102-2186 KANSAS CITY
LINCOLN
402-346-6000 LITTLE ROCK
Facsimile 402-346-1148 NEWPORT BEACH
OKLAHOMA CITY
www.kutakrock.com PASADENA
RICHMOND
SCOTTSDALE
WASHINGTON

April 25, 2001

America First Mortgage Investments, Inc.
399 Park Avenue
36th Floor
New York, NY 10022

Re: Certain Federal Income Tax Consequences

Ladies and Gentlemen:

We have acted as counsel for America First Mortgage Investments, Inc., a
Maryland corporation (the "Company"), in connection with the filing of a
Registration Statement on Form S-2 (the "Registration Statement") under the
Securities Act of 1933, as amended, with respect to the registration of
8,625,000 shares of common stock to be sold by the Company. This opinion is
being furnished in accordance with the requirements of Item 16 of Form S-2 and
Item 601(b)(8) of Regulation S-K.

In the course of our representation, we have reviewed the Registration
Statement, the Articles of Incorporation of the Company, and such other
documents and information as we have deemed necessary and have relied on
certain representations of officers of the Company relating to, among other
things, the operation of the Company and the nature of its assets. For
purposes of our opinion, we have not made an independent investigation of the
facts set forth in such documents or representations, but have relied on the
Company's representation that the information presented in such documents or
otherwise furnished to us accurately and completely describes all material
facts relevant to our opinion. Notwithstanding the foregoing, no facts have
come to our attention that would cause us to question the accuracy and
completeness of such information, facts or documents in any material respect.

In rendering our opinion, we have also considered and relied upon the
Internal Revenue Code of 1986, as amended (the "Code"), the Treasury
Regulations promulgated thereunder (the "Regulations"), pertinent judicial
and administrative authorities and such other authorities as we have
considered relevant. It should be noted that such laws, Code, Regulations,
judicial decisions, administrative interpretations and other authorities are
subject to


KUTAK ROCK LLP

America First Mortgage Investments, Inc.
April 25, 2001
Page 2

change at any time and, in some circumstances, with retroactive effect. A change
in any of the authorities upon which our opinion is based could preclude us
from rendering a similair opinion in the future.

Based on the foregoing, we are of the opinion that (i) commencing with the
Company's taxable year ended December 31, 1998, the Company has been and is
organized in conformity with the requirements for qualification as a real estate
investment trust (a "REIT") under the Code, (ii) the Company's method of
operation has enabled it to meet the requirements for qualification and taxation
as a REIT under the Code and (iii) the Company's proposed method of operation
will enable it to continue to meet the requirements for qualification as a REIT.
We are also of the opinion that the descriptions of the law contained in the
Registration Statement under the caption "Certain Federal Income Tax
Considerations" are correct in all material respects, and the discussion
thereunder fairly summarizes the material federal income tax consequences to a
holder of common stock of the Company. As noted in the Registration Statement,
the Company's qualification and taxation as a REIT depends upon its ability to
meet, through actual annual operating results, certain requirements, including
requirements relating to distributions to its stockholders and the diversity of
its stock ownership, and the various qualification tests imposed under the Code,
the results of which will not be reviewed by us. Accordingly, no assurance can
be given that the actual results of the Company's operation for any one taxable
year will enable the Company to satisfy the requirements for qualification and
taxation as a REIT under the Code.

Other than as expressly stated above, we express no other opinion. This
opinion is intended for the exclusive use of the Company in connection with the
offering of Common Stock under the Registration Statement and it may not be
used, circulated, quoted or relied upon for any other purpose without our prior
written consent. We hereby consent to the filing of this opinion letter as an
exhibit to the Registration Statement and to the reference to this firm under
the heading "Legal Matters" in the prospectus which is part of the Registration
Statement. In giving this consent, we do not thereby admit that we are within
the category of persons whose consent is required under Section 7 of the Act,
the rules and regulations of the Securities and Exchange Commission promulgated
thereunder, or Item 509 of Regulation S-K. This opinion is expressed as of the
date hereof, and we disclaim any undertaking to advise the Company or any other
party of any subsequent changes of the matters stated, represented, or assumed
herein or any subsequent changes in applicable law.


Very truly yours,


/s/ Kutak Rock LLP