EXHIBIT 8.1

                           FULBRIGHT & JAWORSKI L.L.P.
                            1301 MCKINNEY, SUITE 5100
                                HOUSTON, TX 77010
                              PHONE: (713) 651-5151
                               FAX: (713) 651-5246


November 4, 2002


Kaneb Pipe Line Partners, L.P.
2435 N. Central Expressway Suite 700
Richardson, TX 75080-2731

Dear Sirs:

         We have acted as special counsel for Kaneb Pipe Line Partners, L.P., a
Delaware limited partnership (the "Partnership"), in connection with the
offering of units representing limited partner interests ("Units") in the
Partnership pursuant to the Registration Statement on Form S-3 (Registration No.
333-98621) filed with the Securities and Exchange Commission (the "Commission")
by the Partnership on August 23, 2002 as supplemented by the Prospectus
Supplement dated November 4, 2002 (as so supplemented, the "Registration
Statement").

         We have been requested to furnish our opinion as to the material
federal income tax consequences to an investor of acquiring Units in the
offering made pursuant to the prospectus dated September 3, 2002 (the
"Prospectus") included within the Registration Statement. In response to such
request we have prepared the section of the Prospectus entitled "Tax
Considerations" as such opinion.

         We consent to the reference to our firm under the caption "Tax
Considerations" in the Prospectus and to the filing of this confirmation and
consent as an Exhibit to the Registration Statement.

                                       Very truly yours,

                                       /s/ FULBRIGHT & JAWORSKI L.L.P.

                                       Fulbright & Jaworski L.L.P.