SecProbe.io

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                                             April 4, 2007
VIA EDGAR

David R. Humphrey, Accounting Branch Chief
Division of Corporate Finance
U.S. Securities Exchange Commission
100 F Street N.E.
Washington, DC 20549

Re:  AMR Corporation
     Form 10-K filed for the year ended December 31, 2006
     Filed February 22, 2006
     File No. 001-08400

Dear Mr. Humphrey:

This letter sets forth AMR Corporation's (AMR or the
Company) responses with respect to the staff's comment
letter dated March 21, 2007 on AMR's Form 10-K for the year
ended December 31, 2006.  The numbered responses in this
letter correspond to the numbered paragraphs from the
comment letter.  Both the staff's comments and AMR's
responses have been included.

Management's Discussion and Analysis

Liquidity and Capital Resources

  1. We note from your discussion in Note 9-Share Based
     Compensation that you recently changed the settlement terms
     of your Performance Share Awards to be settled in either
     cash or stock, as opposed to settlement in cash only, and as
     such you have reclassified such awards from liabilities to
     equity.  However, it appears there is no disclosure in
     Management's Discussion and Analysis regarding the business
     purpose for this change. As Management's Discussion and
     Analysis is intended to provide explanations for events and
     circumstances through management's eyes, please revise your
     disclosure in future filings to include a discussion of the
     business purpose for this change in settlement terms.
     Please include a copy of your intended disclosure with your
     response.

Response: In order to describe the business purpose for this
change, the Company proposes adding the following paragraph
to our Management Discussion and Analysis in our first
quarter 2007 Form 10-Q.

"As described in the footnotes to the financial statements,
during 2006 and January 2007, the AMR Board of Directors
approved the amendment and restatement of all of the
outstanding performance share plans, the related performance
share agreements and deferred share agreements that required
settlement in cash.  The plans were amended to permit
settlement in cash and/or stock; however, the amendments did
not impact the fair value of the awards under the plans.
These changes were made in connection with a grievance
filed by the Company's three labor unions which asserted
that a cash settlement may be contrary to a component of the
Company's 2003 Annual Incentive Program agreement with the
unions regarding management incentive programs."

Note 7 - Financial Instruments and Risk Management

Fuel Price Risk Management

  2. We note from your disclosure here as well as in
     Management's Discussion and Analysis that you recognized a
     loss of $102 million in Miscellaneous-net for changes in
     market value of hedges that did not qualify for hedge
     accounting during certain periods in 2006.  We also note
     your disclosure on page 65 that indicates the ineffective
     portion of fuel hedging arrangements is immediately
     recognized as a component of Aircraft Fuel Expense.  Please
     explain to us and consider clarifying your disclosure in
     future filings to indicate why you have included this $102
     million loss as a non-operating item instead of a component
     of fuel expenses.

Response:  The Company's accounting policy is to classify
the change in market value of derivative instruments that no
longer represent hedges for accounting purposes as a
component of other income(expense).  This policy was
determined upon adoption and has been applied consistently.

In Footnote 7 to our Form 10-K we describe this accounting
policy.  The ineffective portion of derivative contracts
classified as fuel hedges is immediately recognized as a
component of Aircraft Fuel Expense.  Alternatively, the $102
million charge represented the decline in market value of
derivative instruments no longer classified as fuel hedges
based on the regression models utilized, and therefore was
classified as a component of Other Income.

We will revise future filings to ensure it is clear that the
mark to market adjustment for financial instruments not
accounted for as hedges is recorded as a component of other
income.

AMR acknowledges that the adequacy and accuracy of the
disclosures in its filing with the Commission are the
responsibility of the Company.  The Company acknowledges
that staff comments or changes to disclosures in response to
staff comments do not foreclose the Commission from taking
any action with respect to the filing.  The Company also
acknowledges that staff comments may not be asserted as a
defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United
States.

We appreciate the staff's assistance in this process and
would be pleased to discuss with you at your earliest
convenience any additional comments the staff may have.

                           Very truly yours,

                           /s/ Thomas W. Horton
                           Thomas W. Horton
                           Executive Vice President and Chief Financial Officer

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