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EXHIBIT 8.1
June 20, 2000
Advanta Business Receivables Corp.
639 Isbell Road, Suite 390
Reno, Nevada 89509
Re: ADVANTA BUSINESS CARD MASTER TRUST
ASSET BACKED NOTES
Ladies and Gentlemen:
We have acted as special tax counsel to Advanta Business
Receivables Corp., a Nevada corporation ("ABRC"), in connection with the filing
by ABRC, on behalf of Advanta Business Card Master Trust (the "Trust"), with the
Securities and Exchange Commission under the Securities Act of 1933, as amended
(the "Act"), of a Registration Statement on Form S-3, Registration No.
333-32874, as amended (the "Registration Statement"), registering its Asset
Backed Notes secured by receivables in a portfolio of business revolving credit
card accounts and related assets (the "Notes"). The Notes of a particular Series
will be issued pursuant to a Master Indenture (the "Indenture") between the
Trust and an indenture trustee (the "Indenture Trustee"), substantially in the
form filed as Exhibit 4.1 to the Registration Statement, and a related Series
Supplement to the Indenture (the "Series Supplement") between the Trust and the
Indenture Trustee, substantially in the form filed as Exhibit 4.2 to the
Registration Statement. Capitalized terms used herein and not otherwise defined
shall have the meanings ascribed thereto in the form of Indenture.
We have examined the Registration Statement, the form of
Indenture and the form of Series Supplement. We also have examined the
originals, or duplicates or certified or conformed copies, of such records,
agreements, instruments and other documents and have made such other and further
investigations as we have deemed relevant and necessary in connection with the
opinions expressed herein. As to questions of fact material to this opinion, we
have relied upon certificates of public officials and of officers and
representatives of ABRC.
Based upon the foregoing, and subject to the qualifications
and limitations set forth herein, we are of the opinion that the statements set
forth in the prospectus included in the Registration Statement (the
"Prospectus") under the caption "Federal Income Tax Consequences," insofar as
they purport to constitute summaries of matters of United States federal income
tax law and regulations or legal conclusions with respect thereto, constitute
accurate summaries of the matters described therein in all material respects. We
hereby confirm and adopt the opinions expressly set forth under the caption
"Federal Income Tax Consequences" in the Prospectus.
We are members of the Bar of the State of New York, and we do
not express any opinion herein concerning any law other than the law of the
State of New York and the Federal law of the United States.
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Advanta Business Receivables Corp.
June 20, 2000
Page 2
We hereby consent to the filing of this opinion letter as
Exhibit 8.1 to the Registration Statement and the use of our name under the
captions "Legal Matters," "Federal Income Tax Consequences" and "Summary of
Terms--Tax Status" in the Prospectus included in the Registration Statement.
Very truly yours,
/s/ WOLF, BLOCK, SCHORR and SOLIS-COHEN LLP
WOLF, BLOCK, SCHORR and SOLIS-COHEN LLP
