SEC Comment Letter for U-Haul Holding (UHAL) — Dec 17, 2010

U-Haul Holding Co /NV/ (UHAL, UHAL-B) (CIK 0000004457)
Date: Dec. 17, 2010 · CIK: 0000004457 · Accession: 0000000000-10-075795

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AI Filing Summary & Sentiment

Referenced dates: November 4, 2010

Date

December 17, 2010

Author

Justin Dobbie

Form

UPLOAD

Company

U-Haul Holding Co /NV/ (UHAL, UHAL-B) (CIK 0000004457)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -3561 December 17, 2010 Edward J. Shoen President and Chairman of the Board AMERCO 1325 Airmotive Way, Suite 100 Reno, Nevada 89502 -3239 Form 10 -K Filed June 9, 2010 File No. 001 -11255

Re: AMERCO Amendment No. 1 to Form S -3 Filed December 14 , 2010 File No. 333 -169832

Dear Mr. Shoen:

We have received your response to our prior comment letter to you dated November 29, 2010 and have the following additional comments.

Amended Form S -3 filed December 14, 2010

1. We note your response to comment four of our letter dated November 4, 2010. Please remove the second to last paragraph of the opinion. Such qualifications are inappr opriate.

You may contact John Dan a Brown at (202) 551 -3859 or the undersigned at (202) 551-3469 if you have questions regarding these comments.

Sincerely,
Justin Dobbie
Special Counsel

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -3561

        December 17, 2010

Edward J. Shoen
President and Chairman of the Board
AMERCO
1325 Airmotive Way, Suite 100
Reno, Nevada 89502 -3239

Re: AMERCO
  Amendment No. 1 to
Form S -3
Filed December 14 , 2010
  File No. 333 -169832

  Form 10 -K
  Filed June 9, 2010
File No. 001 -11255

Dear Mr. Shoen:

We have received your response to our prior comment letter to you dated
November 29, 2010 and have the following additional comments.

Amended Form S -3 filed December 14, 2010

1. We note your response to comment four of our letter dated November 4, 2010.
Please remove the second to last paragraph of the opinion.  Such qualifications are
inappr opriate.

You may contact John Dan a Brown at (202) 551 -3859 or the undersigned  at (202)
551-3469  if you have questions regarding these comments.

        Sincerely,

Justin Dobbie
 Special Counsel

cc: Gregory R. Hall, Esq.
 Fax: (480) 606-5528

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