EXHIBIT 8

Exhibit 8



PORTER, WRIGHT, MORRIS & ARTHUR
ATTORNEYS AT LAW
41 SOUTH HIGH STREET
COLUMBUS, OHIO 43215-6194


January 27, 1995


Huntington Bancshares Incorporated
Huntington Bancshares Florida, Inc.
41 South High Street
Columbus, Ohio 43287

Security National Corporation
253 North Orlando Avenue
Maitland, Florida 32751

Ladies and Gentlemen:

We are counsel for Huntington Bancshares Incorporated, a Maryland
corporation and registered bank holding company ("Huntington"), and
Huntington Bancshares Florida, Inc., an Ohio corporation which will become a
registered bank holding company and which is a wholly-owned subsidiary of
Huntington ("Huntington Florida"), in connection with the proposed merger (the
"Merger") of Security National Corporation, a Delaware corporation that is a
registered bank holding company ("Security National"), into Huntington
Florida, pursuant to which the shareholders of Security National will receive
shares of common stock, without par value, of Huntington ("Huntington Common")
in exchange for their shares of common stock, $1.00 par value, of Security
National ("Security National Common"); Huntington Florida will continue to
exist as a wholly-owned subsidiary of Huntington; and the separate existence
and corporate organization of Security National will cease.

We have reviewed the following: Huntington's Articles of Restatement
of Charter; Huntington's Bylaws; Security National's Certificate of
Incorporation; Security National's Bylaws; the Agreement and Plan of Merger,
dated as of July 12, 1994, as amended by the Amendment to Agreement and Plan of
Merger, dated as of January 26, 1995 (collectively, the "Merger Agreement")
each between Huntington Florida and Security National; the Supplemental
Agreement, dated as of July 12, 1994, among Huntington, Huntington Florida, and
Security National (the "Supplemental Agreement"); the corporate action taken
to date in connection with the Merger and the issuance of the Huntington
Common, and certain representations by Huntington, Huntington Florida, and
Security National. Terms defined in the Merger Agreement or the Supplemental
Agreement shall have the same meanings in this opinion letter.

Unless otherwise specified, the section numbers cited herein refer to
sections in the Internal Revenue Code of 1986, as amended (the "Code"). In
connection with the Merger, you have made or will make the following
representations:

a. The fair market value of the shares of Huntington Common and
other consideration to be received by each shareholder of
Security National in the Merger will be approximately equal to
the fair market value of the Security National Common
surrendered in exchange therefor.


b. There is no plan or intention by the shareholders of Security
National who own 5% or more of the outstanding shares of
Security National Common and, to the best of the knowledge of
the management of Security National, there is no plan or
intention on the part of the remaining shareholders of
Security National to sell, exchange, transfer by gift, or
otherwise dispose of a number of shares of Huntington Common
received in the Merger that would reduce the ownership of
Huntington Common by the Security National shareholders to a
number of shares having a value on the Effective Date of the
Merger of less than 50 percent of the total value of all of
the formerly
Huntington Bancshares Incorporated
Huntington Bancshares Florida, Inc.
Security National Corporation
January 27, 1995
Page 2



outstanding shares of Security National Common as of the
same date. For purposes of this representation, shares of
Security National Common surrendered by objecting shareholders
or exchanged for cash in lieu of fractional shares of
Huntington Common will be treated as outstanding Security
National Common on the Effective Date of the Merger as
defined in the Supplemental Agreement. Moreover, shares of
Security National Common and shares of Huntington Common held
by Security National's shareholders and otherwise sold,
redeemed, or disposed of prior or subsequent to the Merger
have been considered in making this representation.


c. Huntington Florida will acquire at least 90 percent of the
fair market value of the net assets and at least 70 percent of
the fair market value of the gross assets held by Security
National immediately prior to the Merger. For purposes of
this representation, amounts paid by Security National to
objecting shareholders, amounts paid by Security National to
shareholders who receive cash or other property, Security
National assets used to pay its reorganization expenses, and
all redemptions and distributions (except for regular,
normal dividends) made by Security National immediately
preceding the Merger will be included as assets of Security
National held immediately prior to the Merger.


d. Prior to the Merger, Huntington will own at least 80% of all
classes of stock of Huntington Florida.


e. Following the Merger, Huntington Florida will not issue
additional shares of its stock that would result in Huntington
losing control of Huntington Florida within the meaning of
Section 368(c) of the Code.


f. Huntington has no plan or intention to reacquire any of its
stock issued in the Merger.


g. Huntington has no plan or intention to liquidate Huntington
Florida; to merge Huntington Florida with and into another
corporation; to sell or otherwise dispose of the stock of
Huntington Florida; or to cause Huntington Florida to sell or
otherwise dispose of any of the assets acquired from Security
National, except for dispositions made in the ordinary course
of business or transfers described in Section 368(a)(2)(C) of
the Code.


h. The liabilities of Security National assumed by Huntington
Florida and the liabilities to which the transferred assets of
Security National are subject were incurred by Security
National in the ordinary course of its business.


i. Following the Merger, Huntington Florida will continue the
historic businesses of Security National or use a significant
portion of Security National's business assets in a business.


j. Huntington, Huntington Florida, and Security National will
each pay their own expenses incurred in connection with the
Merger and will not pay any expenses of the shareholders of
Security National.


k. There is no intercorporate indebtedness existing between
Huntington and Security National or between Huntington Florida
and Security National that was issued, acquired, or will be
settled at a discount.
Huntington Bancshares Incorporated
Huntington Bancshares Florida, Inc.
Security National Corporation
January 27, 1995
Page 3




l. Neither Security National, Huntington, nor Huntington Florida
is an investment company as defined in Section
368(a)(2)(F)(iii) and (iv) of the Code.


m. Neither Security National, Huntington, nor Huntington Florida
is under the jurisdiction of a court in a Title 11 or similar
case within the meaning of Section 368(a)(3)(A) of the Code.


n. The fair market value of the assets of Security National
transferred to Huntington Florida in the Merger will equal or
exceed the sum of the liabilities assumed by Huntington
Florida in the Merger plus the amount of liabilities, if any,
to which the assets to be transferred in the Merger are
subject.


o. No stock of Huntington Florida will be issued in the Merger.


p. The payment of cash in lieu of fractional shares of Huntington
Common is solely for the purpose of avoiding the expense and
inconvenience to Huntington of issuing fractional shares and
does not represent separately bargained-for consideration.
The total cash consideration that will be paid in the
transaction to the Security National shareholders instead of
issuing fractional shares of Huntington Common will not exceed
one percent of the total consideration that will be issued in
the transaction to the Security National shareholders in
exchange for their shares of Security National Common. The
fractional share interests of each Security National
shareholder will be aggregated and no Security National
shareholder will receive cash in an amount equal to or greater
than the value of one full share of Huntington Common.


q. None of the compensation received by any shareholder-employee
of Security National will be separate consideration for, or
allocable to, any of their shares of Security National Common;
none of the shares of Huntington Common received by any
shareholder-employee of Security National will be separate
consideration for, or allocable to, any employment agreement;
and the compensation paid to any shareholder-employee will be
for services actually rendered and will be commensurate with
amounts paid to third parties bargaining at arm's length for
similar services.


r. No material dividends or distributions have been or will be
made with respect to the Security National Common prior to the
Merger except for the normal and customary quarterly dividends
to its shareholders as provided or allowed by the Supplemental
Agreement.


s. In the case of an incentive stock option to acquire shares of
Security National Common granted under the Security National
Stock Option Plan, a holder of such option will not receive
any additional benefits as a result of the conversion of the
option in the Merger.


t. In the case of an incentive stock option to acquire shares of
Security National Common granted under the Security National
Stock Option Plan, immediately after the conversion to an
incentive stock option to purchase shares of Huntington Common
under the Huntington Stock Option Plan, the excess of the
aggregate fair market value of the shares of Huntington Common
subject to the Huntington Stock Option, in each instance, will
not be more than the excess of the aggregate fair market value
of the shares of Security National Common subject to the
Security National Stock Option immediately before its
conversion in the Merger, over the aggregate option prices for
such stock.
Huntington Bancshares Incorporated
Huntington Bancshares Florida, Inc.
Security National Corporation
January 27, 1995
Page 4



u. In the case of an incentive stock option to acquire shares of
Security National Common granted under the Security National
Stock Option Plan, on a share-by-share comparison, the ratio
of the option price to the fair market value the shares of
Huntington Common subject to the Huntington Stock Option
immediately after the conversion in the Merger will not be
more favorable to the optionee than the ratio of the option
price to the fair market value of the shares of Security
National Common subject to the Security National Stock Option
immediately before the conversion.


Based on our understanding of the Merger and subject to the receipt of
the representations set forth above upon the Closing, and assuming the
shareholders of Security National do not sell, exchange, transfer by gift, or
otherwise dispose of a number of shares of Huntington Common received in the
Merger that would reduce the ownership of Huntington Common by the former
shareholders of Security National to a number of shares having a value, as of
the date of the Merger, of less than 50 percent of the total value of all of
the formally outstanding Security National Common as of the same date, we are
of the opinion that:

1. The Merger will constitute a reorganization within the meaning
of Sections 368(a)(1)(A) and 368(a)(2)(D) of the Code and
Huntington, Huntington Florida, and Security National will
each be "a party to a reorganization" within the meaning of
Section 368(b) of the Code.


2. The basis of the assets of Security National received by
Huntington Florida will be the same as the basis of those
assets in the hands of Security National immediately prior to
the Merger.


3. The holding period of the assets of Security National received
by Huntington Florida will, in each instance, include the
period for which such assets were held by Security National.


4. No gain or loss will be recognized by Huntington Florida or
Huntington upon the acquisition by Huntington Florida of
substantially all the assets of Security National in exchange
for shares of Huntington Common, the assumption by Huntington
Florida of the liabilities of Security National, the payment
of cash in lieu of fractional shares of Huntington Common, and
the payment of cash to objecting shareholders of Security
National, if any.


5. Huntington Florida will succeed to and take into account the
items of Security National described in Section 381(c) of the
Code, subject to the conditions and limitations of Sections
381, 382, 383, and 384 of the Code and the Treasury
Regulations thereunder.


6. No gain or loss will be recognized by Security National upon
the transfer of substantially all of its assets to Huntington
Florida in exchange for shares of Huntington Common, the
assumption by Huntington Florida of the liabilities of
Security National, the payment of cash in lieu of fractional
shares of Huntington Common, and the payment of cash to
objecting shareholders, if any.


7. No gain or loss will be recognized by the shareholders of
Security National who exchange their shares of Security
National Common for shares of Huntington Common, except to the
extent of any cash received in lieu of a fractional share of
Huntington Common.


8. The basis of the shares of Huntington Common received by the
shareholders of Security National who receive solely shares of
Huntington Common will be the same as the basis of the shares
of Security National Common surrendered in exchange therefor.
Huntington Bancshares Incorporated
Huntington Bancshares Florida, Inc.
Security National Corporation
January 27, 1995
Page 5




9. The holding period of the shares of Huntington Common received
by a particular shareholder of Security National will include
the period the shares of Security National Common surrendered
in exchange therefor were held by such Security National
shareholder, provided that the Security National Common
surrendered was held as a capital asset in the hands of
such Security National shareholder on the Effective Date.


10. Where solely cash is received by a shareholder of Security
National in exchange for his or her shares of Security
National Common pursuant to the exercise of appraisal
rights, the cash will be treated as having been received by
such shareholder as a distribution in redemption of his or her
shares of Security National Common, subject to the provisions
and limitations of Section 302 of the Code. Where, as a
result of such distribution, a shareholder owns no shares of
Huntington Common either directly or through the application
of Section 318(a) of the Code, the redemption will be a
complete termination of interest within the meaning of Section
302(b)(3) of the Code and such cash will be treated as a
distribution in full payment in exchange for such
shareholder's shares of Security National Common, as provided
in Section 302(a) of the Code. Under Section 1001 of the
Code, gain or (subject to the limitations of Section 267 of
the Code) loss will be realized and recognized to such
shareholders in an amount equal to the difference between the
amount of such cash and the adjusted basis of the Security
National Common shares surrendered, as determined under
Section 1011 of the Code.


11. The payment of cash in lieu of fractional shares of Huntington
Common will be treated for federal income tax purposes as if
the fractional shares were distributed as part of the exchange
and then were redeemed by Huntington; such cash payments will
be treated as having been received as distributions in full
payment in exchange for the stock redeemed subject to the
conditions and limitations of Section 302 of the Code.


12. While not free from doubt, holders of the Security National
Stock Options which are incentive stock options will not
recognize any gain or loss solely as a result of the
conversion of such options into Huntington Stock Options
pursuant to Section 8(d) of the Merger Agreement.


We have given this opinion pursuant to Section 6.05 of the
Supplemental Agreement in connection with the transactions contemplated thereby
and such opinion is not to be relied upon for any other purpose. No opinion is
expressed about the tax treatment of the transaction under other provisions of
the Code and the Treasury Regulations issued thereunder or about the tax
treatment of any conditions existing at the time of, or effects resulting from,
the transaction that are not specifically addressed by the foregoing opinions.
No opinion is expressed as to the effect of state, local, and foreign tax laws.

You should be aware that these opinions represent our conclusions as
to the application of existing law and are based on the representations given
as of the date hereof. We have not independently verified the factual matters
set forth in the representations. Further, we have not obtained an IRS ruling
on this transaction. Unlike a ruling, an opinion of counsel is not binding
upon the IRS, and there can be no assurance that the IRS will not take a
position contrary to the positions reflected in such opinion or that such
opinion will be upheld by the courts if challenged by the IRS. In such event
the tax results described above may be adversely affected.
Huntington Bancshares Incorporated
Huntington Bancshares Florida, Inc.
Security National Corporation
January 27, 1995
Page 6




The statutory provisions, regulations, interpretations, and other
authorities upon which our opinion is based are subject to change, and such
changes could apply retroactively. If there is a change in law prior to
closing, or if the parties are unable to confirm their representations as of
the closing, our opinion is subject to change. No person other than the
addressees named herein may rely on this opinion for any purpose.

We consent to the filing of this opinion as an exhibit to the
Registration Statement.


Very truly yours,

/s/ PORTER, WRIGHT, MORRIS & ARTHUR

PORTER, WRIGHT MORRIS & ARTHUR