<PAGE>

                                                                    Exhibit 8.2

                      [Andrews & Kurth L.L.P. Letterhead]


                                 June 26, 2003


Frontier Oil Corporation
10000 Memorial Drive, Suite 600
Houston, TX 77024-3411

Ladies and Gentlemen:

   We have participated in the preparation of Registration Statement No.
333-105186 on Form S-4 originally filed with the Securities and Exchange
Commission by Front Range Himalaya Corporation, a Wyoming corporation
("Parent") on May 13, 2003 (as amended from time to time and together with
exhibits thereto, the "Registration Statement"), in connection with the planned
merger of Front Range Merger Corporation ("Merger Sub One"), a Delaware
corporation, and direct wholly owned subsidiary of Parent, with and into
Frontier Oil Corporation, a Wyoming corporation ("Frontier"), and the merger of
Himalaya Merger Corporation, a Delaware corporation and direct wholly owned
subsidiary of Parent ("Merger Sub Two") with and into Holly Corporation, a
Delaware corporation ("Holly"), pursuant to the Agreement and Plan of Merger,
dated March 30, 2003, by and among Frontier, Parent, Merger Sub One, Merger Sub
Two and Holly (the "Merger Agreement"), including the discussion set forth in
the Registration Statement under the headings "Material Federal Income Tax
Consequences of the Merger--Tax Consequences of the Merger to Parent, Frontier
and Holly" and "Material Federal Income Tax Consequences of the Merger--Tax
Consequences of the Merger to Frontier Stockholders." The discussion and the
legal conclusions with respect to United States federal income tax matters set
forth therein to Frontier and the stockholders of Frontier reflect our opinion,
and we believe they are accurate and complete in all material respects.

   The transactions contemplated by the Merger Agreement will be referred to
herein as the "Merger." Terms not otherwise defined herein shall have the
meanings ascribed to them in the Merger Agreement. Our opinion is based upon
and conditioned upon the initial and continuing accuracy of the statements,
representations and assumptions set forth in the Merger Agreement, the
Registration Statement, and officer's certificates delivered to us by Frontier,
Holly, Parent, Merger Sub One and Merger Sub Two. We have also assumed that all
representations made "to the best knowledge of" any person will be true,
correct and complete as if made without that qualification. Any inaccuracies in
any of the aforementioned statements, representations, or assumptions or breach
or failure of any of the aforementioned covenants could adversely affect our
opinion.

   In rendering our opinion, we have assumed the Merger will occur in the
manner contemplated by the Registration Statement and in accordance with the
Merger Agreement and there are no arrangements other than those set forth in
the Merger Agreement between the parties thereto. Our opinion is based upon
provisions of the United States Internal Revenue Code of 1986, as amended,
regulations promulgated thereunder and interpretations thereof by the Internal
Revenue Service and the courts, all as of the date hereof, all of which are
subject to change with prospective or retroactive effect, and our opinion could
be adversely affected or rendered obsolete by any such change. We provide no
assurance that the legal authorities upon which this opinion is based will not
be amended, revoked or modified (with or without retroactive effect) in a
manner which would affect or change our conclusions.

   Our opinion is limited to the matters set forth herein, and no opinion is
intended to be implied or may be inferred beyond those expressly stated herein.
Specifically, no opinions are expressed with respect to the tax consequences of
the Merger or the ownership of Parent Stock under any foreign, state, or local
tax law.

<PAGE>

Frontier Oil Corporation
June [  ], 2003
Page 2


   In addition, our opinion is based on the assumption that the matter will be
properly presented to the applicable court. Furthermore, our opinion is not
binding on the Internal Revenue Service or a court. Finally, we must note that
our opinion represents merely our best legal judgment on the matters presented
and that others may disagree with our conclusions. Thus, there can be no
assurance that the Internal Revenue Service will not take contrary positions or
that a court would agree with our opinion if litigated.

   We hereby consent to the use of our name in the Registration Statement and
to the filing of this opinion as part of the Registration Statement. In giving
this consent, we do not hereby admit that we are within the category of persons
whose consent is required under Section 7 of the Securities Act of 1933 and the
rules and regulations of the Securities and Exchange Commission.

                                          Very truly yours,

                                          /s/  Andrews & Kurth L.L.P.