<DOCUMENT>
<TYPE>EX-8.0
<SEQUENCE>4
<FILENAME>dex80.txt
<DESCRIPTION>EXHIBIT 8.0
<TEXT>
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                                                                     EXHIBIT 8.0

                  [Letterhead of Muldoon Murphy & Faucette LLP]




                                January 30, 2003


First Capital, Inc.
220 Federal Drive, NW
Corydon, Indiana 47112

Gentlemen:

         We have acted as special counsel to First Capital, Inc., an Indiana
corporation ("First Capital"), in connection with the proposed merger (the
"Merger") of Hometown Bancshares, Inc., an Indiana corporation ("Hometown"),
with and into First Capital, pursuant to the Agreement and Plan of Merger, dated
as of September 25, 2002, by and between Hometown and First Capital (the
"Agreement"). At your request, and in connection with the filing of the
registration statement on Form S-4 filed with the Securities and Exchange
Commission in connection with the Merger (the "Registration Statement"), we are
rendering our opinion concerning certain federal income tax consequences of the
Merger.

         For purposes of the opinion set forth below, we have relied, with the
consent of Hometown and the consent of First Capital, upon the accuracy and
completeness of the statements and representations (which statements and
representations we have neither investigated nor verified) contained,
respectively, in the certificates of the officers of Hometown and First Capital
dated the date hereof, and have assumed that such statements and representations
will be complete and accurate as of the Effective Time and that all such
statements and representations made to the knowledge of any person or entity or
with similar qualification are and will be true and correct as if made without
such qualification. We have also relied upon the accuracy of the Registration
Statement and the proxy statement-prospectus (the "Proxy Statement-Prospectus")
contained therein, each as amended or supplemented through the date hereof. Any
capitalized term used and not defined herein has the meaning given to it in the
Agreement.

         We have also assumed that: (i) the transactions contemplated by the
Agreement will be consummated in accordance therewith and as described in the
Proxy Statement-Prospectus (and no transaction or condition described therein
and affecting this opinion will be waived by any party); (ii) the Merger will
qualify as a statutory merger under the applicable laws of the State of

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First Capital, Inc.

January 30, 2003

Page 2

Indiana; and (iii) the Merger will be reported by Hometown and First Capital on
their respective federal income tax returns in a manner consistent with the
opinion set forth below.

         Based upon and subject to the foregoing, it is our opinion, under
currently applicable United States federal income tax law, that:

         1.    The Merger will constitute a reorganization within the meaning of
               Section 368(a) of the Internal Revenue Code of 1986, as amended
               (the "Code");

         2.    First Capital and Hometown will each be a party to that
               reorganization within the meaning of Section 368(b) of the Code;
               and

         3.    No gain or loss will be recognized by holders of Hometown Common
               Stock who exchange all of their Hometown Common Stock solely for
               First Capital Common Stock pursuant to the Merger (except with
               respect to any cash received in lieu of a fractional share
               interest in First Capital Common Stock).

         We hereby consent to the filing of this opinion with the Securities and
Exchange Commission as an exhibit to the Registration Statement, and to the
references therein to us. 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 Securities Act of 1933, as amended.

         This opinion relates solely to certain United States federal income tax
consequences of the Merger and no opinion is expressed as to the tax
consequences under any foreign, state or local tax law or under any federal tax
laws other than those pertaining to the income tax. This opinion is based upon
existing statutory, regulatory, and judicial authority, any of which may be
changed at any time with retroactive effect. Further, no opinion is expressed
with respect to the United States federal income tax consequences to Hometown
stockholders subject to special treatment under United States federal income tax
law, such as Hometown stockholders, if any, who hold Hometown Common Stock other
than as a capital asset, who received Hometown Common Stock upon the exercise of
employee stock options, through a tax-qualified retirement plan or otherwise as
compensation, who hold Hometown Common Stock as part of a "hedge," "straddle,"
"constructive sale" or "conversion transaction," or who are banks or trusts,
tax-exempt organizations, insurance companies, dealers in securities or foreign
currency, traders in securities who elect to apply a mark-to-market method of
accounting, pass-through entities and investors in such entities, or foreign
persons.

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First Capital, Inc.

January 30, 2003

Page 3

         We assume no obligation to revise or supplement this opinion should the
present federal income tax laws be changed by any legislation, judicial
decisions or otherwise.

                                              Very truly yours,

                                              /s/ MULDOON MURPHY & FAUCETTE LLP

                                              MULDOON MURPHY & FAUCETTE LLP

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