Exhibit 8

                                                              September 25, 1998


Huntington Bancshares Incorporated
41 South High Street
Columbus, Ohio  43287

Ladies and Gentlemen:

         As special tax counsel to Huntington Capital I (the "Trust") and
Huntington Bancshares Incorporated in connection with the exchange offer by the
Trust of $15,000,000 of its Floating Rate Capital Securities pursuant to the
Prospectus which forms a part of Post-Effective Amendment No. 1 to Registration
Statement on Form S-4, filed with the Securities and Exchange Commission on
September 25, 1998 (the "Prospectus"), and assuming that the operative documents
described in the Prospectus will be performed in accordance with the terms
described therein, we hereby confirm to you our opinion as set forth under the
heading "Certain United States Federal Income Tax Consequences" in the
Prospectus, subject to the limitations set forth therein.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the references to us under the hearing "Certain
United States Federal Income Tax Consequences" in the Prospectus. In giving such
consent, we do not thereby admit that we are in the category of persons whose
consent is required under Section 7 of the Act.

                                Very truly yours,

                                /s/ Porter, Wright, Morris & Arthur

                                PORTER, WRIGHT, MORRIS & ARTHUR