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CORRESP
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      Response to SEC Letter dated 01-26-07

    February
      8, 2007

    Via
      EDGARLink Transmission and Facsimile

    Mr.
      David R. Humphrey

    Branch
      Chief

    Unites
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    100
      F Street N.E.

    Mail
      Stop 3561

    Washington,
      D.C. 20549

    Re:
      AMERCO

    Form
      10-K for the year ended March 31, 2006

    Filed
      June 13, 2006

    File
      No. 001-10275

    Dear
      Mr.
      Humphrey

    This
      letter responds to the Staff’s comments concerning our Form 10-K for the year
      ended March 31, 2006. We appreciate that the purpose of your review is to assist
      us in our compliance with the applicable disclosure requirements and to enhance
      the overall disclosure in our filings.

    For
      your
      convenience, the Staff’s comments are repeated below in bold, with our response
      to each comment set forth immediately thereafter.

    Form
      10-K for the fiscal year ended March 31, 2006

    Item
      7 - Management’s Discussion and Analysis

    Liquidity
      and Capital Resources, page 38

    1.  At
      the beginning of your discussion of liquidity and capital resources, you may
      want to consider explaining your overall capital structure with respect to
      the
      general availability of the assets of your insurance subsidiaries to satisfy
      the
      obligations of the parent company and certain of its subsidiaries. In this
      regard, you may want to consider including a table that separately presents
      the
      assets and obligations of your insurance and non-insurance
      operations.

    In
      response to the Staff’s comment, we advise the Staff as follows:

    Mr.
      David
      R. Humphrey, Branch Chief

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    February
      8, 2007

    Page
      2

    In
      our
      future filings with the Commission, we will ensure that our disclosure will
      address this comment, as appropriate. We note that our December 31, 2006 Form
      10-Q filed on February 7, 2007 included the following disclosure:

    At
      December 31, 2006, cash and cash equivalents totaled $313.1 million, compared
      with $155.5 million on March 31, 2006. The assets of our insurance subsidiaries
      are generally unavailable to fulfill the obligations of non-insurance operations
      (AMERCO, U-Haul and Real Estate). The assets of SAC Holding II are completely
      unavailable to satisfy any of the Company’s obligations. As of December 31, 2006
      the cash and cash equivalents, other financial assets (receivables, short-term
      investments, other investments, fixed maturities, and related party assets)
      and
      obligations of each operating segment were:

                  Moving
                    &

                  SAC

                  Storage

                  RepWest

                  Oxford

                  Holding
                    II

                  Cash
                    & cash equivalents

                  297,515

                  7,395

                  8,221

                  -

                  Other
                    financial assets

                  359,280

                  416,583

                  654

                  -

                  Debt
                    obligations

                  1,223,405

                  -

                  -

                  75,253

    2.  In
      the second paragraph, you disclose that your total debt represents 1.4 times
      stockholders equity. Its unclear how this ratio supports the assertion that
      your
      financial condition is strong. Please explain supplementally and consider
      revising your disclosure to explain how the aforementioned ratio is an
      indication of your financial strength.

    In
      response to the Staff’s comment, we advise the Staff as follows:

    In
      our
      future filings with the Commission, we will ensure that our disclosure will
      address this comment, as appropriate. We note that in our December 31, 2006
      Form
      10-Q filed on February 7, 2007 we removed this ratio from our disclosure. We
      have re-evaluated the debt to stockholders equity ratio and do not consider
      this
      to be the most effective method of conveying or evaluating our financial
      condition, without additional facts. We believe that our additional disclosure
      listed in Item #1 above combined with our disclosure as discussed in Item #3
      below provide our justification for our statement regarding the strength of
      our
      financial condition.

    3.  In
      the summary of this section on page 41, you cross reference footnote 9 for
      a
      more detailed discussion of your long-term debt and borrowing capacity. However,
      we believe your MD&A should include a discussion of these matters from
      management’s point of view. For example, by reference to exhibit 10.79 of your
      filing, we note that your credit agreement with Merrill Lynch includes

    Mr.
      David
      R. Humphrey, Branch Chief

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    February
      8, 2007

    Page
      3

    a
      covenant regarding the “Fleet Owner Cash Flow Ratio” and this covenant appears
      to limit the level of borrowings. As appropriate, please consider the need
      to
      provide an overall discussion of your borrowing levels and remaining borrowing
      capacity in MD&A.

      In
        response to the Staff’s comment, we advise the Staff as
        follows:

    In
      our
      future filings with the Commission, we will ensure that our disclosure will
      address this comment, as appropriate. We note that in our December 31, 2006
      Form
      10-Q filed on February 7, 2007 we expanded our Management Discussion and
      Analysis (MD&A) disclosure to provide additional explanation regarding our
      debt as follows:

    The
      Company’s borrowing strategy is primarily focused on asset-backed financing. As
      part of this strategy, the Company seeks to ladder maturities and for loans
      with
      floating rates, fix these rates through the use of interest rate swaps. While
      each of these loans typically contains provisions governing the amount that
      can
      be borrowed in relation to specific assets, the overall structure is flexible
      with no limits on overall Company borrowings. Management feels it has adequate
      liquidity between cash and cash equivalents and unused borrowing capacity in
      existing facilities. At December 31, 2006 the Company had cash availability
      under existing credit facilities of $320.0 million. We believe that there are
      additional opportunities for leverage in our existing capital
      structure.

    Off
      Balance Sheet Arrangements, page 42

    4.  Please
      expand your disclosure to address, in further detail, the nature and business
      purpose for your off-balance sheet arrangements as required by Item
      303(a)(4)(i)(A) of Regulation S-K. For example, you state that you have used
      off-balance sheet arrangements in connection with the expansion of your
      self-storage business. However, it is unclear why this business could not have
      been expanded within your consolidated operations.

     In
      response to the Staff’s comment, we advise the Staff as
      follows:

    In
      our
      future filings with the Commission, we will ensure that our disclosure will
      address this comment, as appropriate. We note that our December 31, 2006 Form
      10-Q filed on February 7, 2007 included the following expanded
      disclosure:

    Historically,
      AMERCO used off-balance sheet arrangements in connection with the expansion
      of
      our self-storage business. These arrangements were primarily used when the
      Company’s overall borrowing structure was more limited. The Company does not

    Mr.
      David
      R. Humphrey, Branch Chief

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    February
      8, 2007

    Page
      4

    face
      similar borrowing limitations currently and off-balance sheet arrangements
      have
      not been utilized in our self-storage expansion in recent years. In the future,
      the Company will continue to identify and consider off-balance sheet
      opportunities to the extent such arrangements would be economically advantageous
      to the Company and its stockholders.

    5.  It
      appears from your disclosures on page F-37 that you guarantee certain related
      party debt instruments (e.g. support party agreement with Private Mini). As
      such, please revise your disclosures to include the total dollar amount related
      to these agreements and any other obligations that would require disclosure
      under Item 303(a)(4)(ii) of Regulation S-K.

     In
      response to the Staff’s comment, we advise the Staff as
      follows:

    In
      our
      future filings with the Commission, we will ensure that our disclosure will
      address this comment, as appropriate. AMERCO was providing financial guarantees
      via support party agreements to Private Mini in the amounts of $55 million
      and
      $70 million in 2003. At March 31, 2003 the $55 million obligation was triggered
      and AMERCO satisfied this in a cash payment. AMERCO recorded a receivable from
      Private Mini at that time for $55 million. This receivable was restructured
      into
      a note due from Private Mini to AMERCO and is shown in the Related Party
      Receivable line of our financial statements. Effective July 15, 2005 the $70
      million obligation was terminated by the lender and AMERCO no longer has any
      financial obligation related to this item. Therefore, at March 31, 2006 AMERCO
      did not have any financial support or guarantee agreements with unconsolidated
      entities constituting off-balance sheet arrangements. The various legal
      subsidiaries of AMERCO and U-Haul regularly provide guarantees to each other
      as
      part of our debt arrangements. In our December 31, 2006 Form 10-Q filing the
      Company revised its disclosure in an attempt to alleviate any future
      confusion.

    Item
      8 - Financial Statements and Supplementary Data

    Note
      1 - Basis of Presentation, page F-8

    6.  The
      operating results and financial position of your consolidated insurance
      operations are determined as of December 31 of each year. As such, please revise
      your disclosures to address the necessity for the use of different closing
      dates
      and the effect of intervening event that materially affect the financial
      position or results of operations or lack thereof.

     In
      response to the Staff’s comment, we advise the Staff as
      follows:

    Mr.
      David
      R. Humphrey, Branch Chief

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    February
      8, 2007

    Page
      5

    In
      our
      future filings with the Commission, we will ensure that our disclosure will
      address this comment, as appropriate. We note that our December 31, 2006 Form
      10-Q filed on February 7, 2007 included the following disclosure:

    Our
      insurance companies’ financial reporting processes conform to calendar year
      reporting as required by state insurance departments. Management believes that
      consolidating their calendar year quarters into our fiscal year quarterly
      financial statements does not materially affect the financial position or
      results of operations. The Company discloses any material events occurring
      during the intervening period.

    Note
      3 - Accounting Policies

    Property,
      Plant and Equipment, F-12

    7.  We
      note that gains and losses on dispositions of property, plant and equipment
      are
      netted against depreciation expense when realized. In this regard, please tell
      us what consideration has been given to the guidance in SAB Topic
      5B.

     In
      response to the Staff’s comment, we advise the Staff as
      follows:

    The
      Company has historically netted gains and losses on dispositions of property,
      plant and equipment with depreciation expense; our intent is to fully utilize
      the useful lives of rental trucks and trailers and it is expected that minimal
      gains or losses will be recognized on disposition. If we were able to precisely
      estimate useful lives and salvage values for our rental fleet, gains or losses
      on the disposition would be inconsequential and would instead be presented
      as
      higher or lower depreciation. Therefore, we view gains or losses on the
      disposition of equipment to theoretically represent additional or less
      depreciation expense and should be netted with reported depreciation expense.
      The effect on depreciation is displayed in our Statement of Cash Flows included
      in the Form 10-K for all periods.

    FASB
      Statement No. 144 requires impairment losses and gains from disposal be included
      in income from operations and requires disclosure of which caption it is in
      if
      not presented in a separate caption. By not specifying a caption, the FASB
      leaves room for company judgment about where to include the gains and
      losses.

    Additionally,
      paragraph 38 of the AICPA Exposure Draft on property, plant and equipment would
      have required the net book value of retired components of property to be charged
      to depreciation expense. The Draft did not discuss where to classify the
      proceeds from sale, but logically if the net book value is charged to
      depreciation expense, the proceeds received in a sale would represent salvage
      value and be reported in the same

    Mr.
      David
      R. Humphrey, Branch Chief

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    February
      8, 2007

    Page
      6

    line
      in
      the income statement. The logic for the proposed classification is that the
      retirement of the asset requires a final true-up of depreciation.

    In
      the
      Company’s judgment, we believe that presenting gains and losses on the disposal
      of equipment together with depreciation expense is acceptable under
      GAAP.

    8.  Please
      tell us your basis for capitalizing and amortizing major overhauls. Further,
      provide us with the length of the amortization period related to the major
      overhauls and equipment as well as the authoritative accounting literature
      that
      supports your conclusions.

     In
      response to the Staff’s comment, we advise the Staff as
      follows:

    The
      Company’s accounting policy for capitalizing and amortizing major overhauls is
      based in the AICPA’s Airline Audit Guide (as amended by FASB Staff Position No.
      AUG AIR-1, Accounting
      for Planned Maintenance Activities),
      which
      is applicable to entities in all industries. The Company’s overhauls do not
      represent betterments, i.e. the overhauls are not considered to improve the
      rental trucks as compared to the original condition at acquisition; therefore,
      any of the three remaining alternative accounting methods permitted by the
      Airline Audit Guide are acceptable. The Company follows the deferral method
      of
      accounting for major overhauls in which engine ove