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                                                                     EXHIBIT 8.2

                                January 2, 2002

Direct Dial                                                           Client No.
(213) 229-7000                                                     C 89576-00008

Schuler Homes, Inc.
400 Continental Blvd., Suite 100
El Segundo, California 90245

     Re: Acquisition of Schuler Homes, Inc. by D.R. Horton, Inc.

Ladies and Gentlemen:

     You have requested our opinion regarding certain federal income tax
consequences of the proposed merger (the "Merger") of Schuler Homes, Inc., a
Delaware corporation ("Schuler"), with and into D.R. Horton, Inc., a Delaware
corporation ("DHI").

     In formulating our opinion, we have reviewed such documents as we deemed
necessary or appropriate, including the Agreement and Plan of Merger, dated as
of October 22, 2001, by and between DHI and Schuler, as amended as of November
8, 2001 (the "Merger Agreement"), and the Joint Proxy Statement/Prospectus of
DHI and Schuler that is included in the Registration Statement on Form S-4, as
filed with the U.S. Securities and Exchange Commission on January 2, 2002 (the
"Prospectus").

     Our opinion set forth below assumes (i) the accuracy of the statements and
facts concerning the Merger set forth in the Merger Agreement and the
Prospectus; (ii) that the Merger will be consummated in the manner contemplated
by, and in accordance with, the terms set forth in the Merger Agreement and the
Prospectus; and (iii) the accuracy of (a) the representations made to us by
Schuler, which are set forth in a Certificate dated January 2, 2002, and (b)
the representations made to us by DHI, which are set forth in a Certificate
dated January 2, 2002.

     Based upon the foregoing and in reliance thereon, and subject to the
qualifications, exceptions, assumptions and limitations herein contained, we are
of the opinion that:

     1.   The Merger will be treated for U.S. federal income tax purposes as a
          reorganization within the meaning of Section 368(a) of the Internal
          Revenue Code of 1986, as amended (the "Code").

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Schuler Homes, Inc.
January 2, 2002
Page 2

     2.   DHI and Schuler will each be treated as a party to the reorganization
          within the meaning of Section 368(b) of the Code.

Furthermore, the discussion under the caption "United States Federal Income Tax
Consequences of the Merger" in the Prospectus accurately describes the foregoing
opinion and the material federal income tax consequences of the Merger. We
express no opinion concerning any tax consequences of the Merger other than
those specifically set forth herein.

     Our opinion is based on current provisions of the Code, Treasury
Regulations promulgated thereunder, published pronouncements of the Internal
Revenue Service, and case law, any of which may be changed at any time with
retroactive effect. Any change in applicable law or the facts and circumstances
surrounding the Merger, or any inaccuracy in the statements, facts, assumptions,
and representations on which we relied, may affect the continuing validity of
the opinion set forth herein. We assume no responsibility to inform you of any
such changes or inaccuracy that may occur or come to our attention.

     This opinion has been furnished to you solely in connection with the
transactions described herein and may not be relied upon by any other person or
by you for any other purpose without our specific, prior, written consent. We
hereby consent to the filing of this opinion as an exhibit to the Registration
Statement, to references to this opinion in the Registration Statement, and to
the use of our name under the caption "United States Federal Income Tax
Consequences of the Merger." In giving this consent, we do not admit that we are
included in the category of persons whose consent is required under Section 7 of
the Securities Act of 1933, as amended, or the rules and regulations promulgated
thereunder.

                                       Very truly yours,



                                       GIBSON, DUNN & CRUTCHER LLP

SLT/ESB

