SecProbe.io

Mail Stop 3561          January 29, 2009  Edward J. Shoen  President and Chairman of the Board AMERCO  1325 Airmotive Way, Suite 100 Reno, NV 89502-3239
Re: AMERCO
Form 10-K for the Fiscal Year ended March 31, 2008
  Filed June 4, 2008
  Schedule 14A filed July 15, 2008
  File No. 001-11255

Dear Mr. Shoen:
We have conducted a targeted review of the above referenced filing for the legal
issues noted below.  We think you should revi se your future filings in response to these
comments.  If you disagree, we will consider your explanation as to why our comments are
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so
we may better understand your disclosure.  Af ter reviewing this information, we may raise
additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Please respond to confirm that such comme nts will be complied with, or, if certain
of the comments are deemed inappropriate, advi se the staff of your reason.  Your response
should be submitted in electronic form, under the label “corresp” with a copy to the staff.
Please respond within ten (10) business days.

Edward J. Shoen
AMERCO
January 29, 2009 Page 2

Form 10-K

Risk Factors, page 7
1. In future filings, please add a risk factor  discussing the impact of the current
economic climate on your business.
 Signatures

2. We note that your principal financial officer  has not signed the report.  In future
filings, please revise your signature page so  that the appropriate individual signs in
that capacity.   Please note that if a ny person occupies more than one of the
positions specified in General Instruction D(2)(a) to Form 10-K you should indicate
each capacity in which that person signs the report. See Signatures on Form 10-K
and General Instruction D( 2)(a) to Form 10-K

Schedule 14A

Compensation Discussion and Analysis, page 15
 Elements Used to Achieve Compensation Objectives, page 16

3. In future filings, please expand your Co mpensation Discussion & Analysis to
provide more detailed analysis  of the elements and levels of compensation paid to
the named executive officers.  For exampl e, discuss in greater detail how you
determine the base salary of each named executive officer and the amount of discretionary cash bonus available to each  named executive officer.  Throughout
your Compensation Discussion & Analysis, and as to each compensation element, you should provide an analysis of ho w you arrived at, and why you paid, each
particular level and form of compensa tion. To the extent that certain named
executive officers are treated differently  than others, your disclosure should
highlight and explain these differences. Y ou should also describe the reasons why
the committee believes that the amounts paid to each named executive officer are appropriate in light of the various items it considered in making specific
compensation decisions.  Refer to Item 402( b) of Regulation S-K.  Consider also
the staff’s Compliance and Disclosure Interpretations (Updated 7/3/08 ) at
www.sec.gov
.

Summary Compensation Table, page 17
4. In future filings, please revise the tabula r presentation, including column headings,
to conform to the Summary Compensation Table requirement in Item 402(c) of
Regulation S-K.

Edward J. Shoen
AMERCO
January 29, 2009
Page 3

* * * * *

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and that they have provided all information investors
require for an informed investment decision.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.     In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 ‚ the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of  the United States.
 In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
If you have any questions regarding these comments, you may contact J. Nolan
McWilliams at (202) 551-3217.  If you need furt her assistance, you may contact me at (202)
551-3314.
Regards,
           D a n i e l  M o r r i s          A t t o r n e y - A d v i s o r