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                                                                     EXHIBIT 8.1


                  [BROWN, PARKER & LEAHY, L.L.P. LETTERHEAD]



                                 ______, 1997


Pinemont Bank
12130 Hempstead Highway
Houston, Texas  77092

Gentlemen:

        You have asked for our opinion regarding certain federal income tax 
consequences of the proposed merger ("Merger") of Pinemont Bank, a Texas banking
association ("Pinemont") with and into Southwest Bank of Texas National 
Association, a national banking association ("Southwest").  Southwest is a 
wholly-owned direct subsidiary of Southwest Bancorporation of Texas 
Inc., a Texas corporation ("Parent").

        In rendering the limited opinion expressed below, we have examined and 
relied upon originals or copies of the Merger Agreement, the proxy 
statement/prospectus of Southwest dated _______________, 1997 and such documents
and matters as we have considered necessary.

        For the purpose of these opinions, we have assumed (i) the due 
authorization, execution and delivery of each document by the parties thereto, 
(ii) the genuineness of all signatures, (iii) authenticity of all documents 
submitted to us as originals, and (iv) the conformity with the originals of all 
documents submitted to us as copies.  With respect to certain matters of 
material fact to these opinions, we have relied upon certificates of 
representatives of Pinemont.  Except as specifically described herein, we have 
not undertaken any independent investigation to determine existence or absence 
of such facts. No inferences to our knowledge of the existence of such facts 
should be drawn from the fact of our representation of Pinemont or any other 
person.  For purposes of these opinions, we assume that none of such information
contains any untrue statement of a material fact or omits any material fact 
necessary to make the statements made under the circumstances which they are 
made, not misleading.  Furthermore, we have assumed and these opinions are 
conditioned upon Pinemont, Parent and Southwest being organized and operated in 
accordance with the description in the Merger Agreement and the Merger being 
consummated as described in the Merger Agreement.

        Further, the opinions are also based upon the following assumptions and 
conditions: (1) the Pinemont shareholders are acquiring Parent common stock, 
$1.00 par value ("Parent Common Stock"), pursuant to the Merger for their own 
account and intend to hold such stock for their own interest without any 
preconceived disposition plan, (2) the historic Pinemont business will be 
continued by Southwest after the Merger, (3) Southwest will hold all or 
substantially all of the historic assets of Southwest and Pinemont after the 
Merger, (4) the Pinemont shareholders have

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May 27, 1997
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not disposed of or acquired Pinemont stock in contemplation of the Merger, and 
(5) Parent has no preconceived plan or intention to dispose of the Southwest 
stock or liquidate Southwest after the Merger.

        We have not made a review of the laws of any jurisdiction other than 
Federal income tax laws of the United States of America.  Accordingly, the 
opinions expressed herein are limited exclusively to the income tax laws of the 
United States of America.

        The opinions are expressly limited to the matters enumerated below.  No 
opinions should be inferred as to any other matters (tax or otherwise).

        The opinions are not binding on the Internal Revenue Service, or other
agencies or the courts and are limited to the interpretation of the Internal
Revenue Code of 1986, as amended ("Code"), and concomitant regulations. Future
administrative and legislative changes, court decisions or governmental
interpretations may significantly modify the opinions expressed herein. While
the opinions are based upon our best interpretation of existing laws and express
what we believe a court would conclude at that time, no assurances can be given
that such interpretations would be followed if they became subject to judicial
or administrative proceedings.

        These opinions are as of the date hereof, we undertake no, and hereby 
disclaim any, obligation to advise you of any change.  Further, these opinions 
are solely for the benefit of the addressee; these opinions may not be relied in
any manner, nor used, by any other person without the prior written approval of 
the Firm.

        These opinions are subject to interpretation and construction under the 
laws of the State of Texas.  To the extent permitted by applicable law, any 
cause of action relating to an opinion expressed herein shall be brought in a 
federal or state court sitting in Harris County, Texas.

        Based on the foregoing, we advise you that in our opinion for federal
income tax purposes:

        1.   The Merger will be treated for federal income tax purposes as a
             reorganization within the meaning of Section 368(a) of the Code;

        2.   Each of Parent, Pinemont and Southwest will be a party to the
             reorganization within the meaning of Section 368(b) of the Code;

        3.   No gain or loss will be recognized by Southwest, Parent or Pinemont
             as a result of the Merger;

        4.   The basis of the Pinemont shareholders in the Parent Common Stock
             received in the Merger will be the same as the basis of the
             Pinemont common stock surrendered in exchange therefor (reduced by
             the excess, if any, of the cash received over the amount of gain
             recognized on the exchange); and
 

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        5.   The holding period of the shares of Parent Common Stock received by
             a shareholder will include the holding period of the shares of
             Pinemont common stock surrendered therefor, provided that such
             Pinemont common stock was held as a capital asset by such
             shareholder.


                                        Very truly yours,

                                        BROWN, PARKER & LEAHY, L.L.P.