SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

June 22, 2005

Mr. Daniel R. Ouzts
Vice President of Finance and Treasurer
Medicore, Inc.
2337 West 76th Street
Hialeah, FL  33016

Re:	Medicore, Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2004
	Filed March 31, 2005
	File No. 000-06906

Dear Mr. Ouzts:

      We have limited our review of your filing to those issues we
have addressed in our comments.     In our comments, we ask you to
provide us with information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may raise additional
comments.

	Please understand that the purpose of our review 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.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and ..., page 40

Critical Accounting Policies and Estimates, page 52

1. Please provide to us the following about your accounting for
revenue and accounts receivable:

* The steps you take in collecting accounts receivable, including
patient co-payments;

* Your policy with respect to determining when a receivable is
recorded as a bad debt and when a write off is recorded, including
any thresholds (amount and age); and,

* State whether your billing system generates contractual
adjustments
based on fee schedules for the patient`s insurance plan for each
patient encounter or if an estimate of contractual allowances is
made; if an estimate is made, state what factors are considered in
determining the estimate.

2. Please explain to us the following:  (a) why your receivables
balance at December 31, 2004 increased substantially higher than
your
total sales for 2004, (b) why your allowance increased during 2004
and (c) why bad debt expense decreased during 2003 as compared to
2002, and increased during 2004 as compared to 2003.

3. Please provide to us the following information about your
accounts
receivable:

* For each period presented, tell us and quantify the amount of
changes in estimates of prior period contractual adjustments that
you
recorded during the current period. For example, for 2004, this
amount would represent the amount of the difference between
estimates
of contractual adjustments for services provided in 2003 and the
amount of the new estimate or settlement amount that was recorded
during 2004.

* Explain and quantify the reasonably possible effects that a
change
in estimate of unsettled amounts from 3rd party payors as of the
latest balance sheet date could have on financial position and
operations.

* Disaggregate self-payors from the commercial insurers and
private
payors in your comparative tabular format for payor mix
concentrations and include the related aging of accounts
receivable.
The aging schedule may be based on management`s own reporting
criteria (i.e. unbilled, less than 30 days, 30 to 60 days etc.) or
some other reasonable presentation.  At a minimum, indicate the
past
due amounts and a breakdown by payor classification (i.e.
Medicare,
Medicaid, managed care and other, and self-pay).  We would expect
self-pay to be separately classified from any other grouping.  If
your billing system does not have the capacity to provide an aging
schedule of your receivables, explain to us that fact and clarify
how
this affects your ability to estimate your allowance for bad
debts.

* If you have amounts that are pending approval from third party
payors (i.e. Medicaid pending), please provide the balances of
such
amounts, where they have been classified in your aging buckets,
and
what payor classification they have been grouped with.  If amounts
are classified outside of self-pay, tell us why this
classification
is appropriate, and provide the historical percentage of amounts
that
get reclassified into self-pay.

* The days sales outstanding for each period presented.

Item 15(a)(1) and (2) - Financial Statements, page F-1

Consolidated Statement of Operations, page F-5

4. Please tell us why it is appropriate for you to include a gain
on
the sale of a former subsidiary as part of your continuing
operations
in this statement and your consolidated statements of cash flows,
when (a) page F-26 apparently indicates that the sale was of your
ownership in Techdyne, Inc. and (b) page 39 apparently indicates
that
the sale had originally been included as part of discontinued
operations.

Consolidated Statements of Stockholders` Equity, page F-6

5. Please tell us how you account for exercises of subsidiary
stock
options and why it is appropriate for you reduce equity for these
exercises.  In so doing, please cite the specific literature (by
pronouncement and paragraph) supporting this.

Notes to Consolidated Financial Statements, page F-8

6. Please tell us the nature, terms and amounts of the put and
call
options on the assets of the Georgia facility that we noted on
page 7
and tell us how you have accounted for them.  In addition, please
explain to us whether the options are subject to the requirements
of
SFAS 133 and how your accounting and disclosures comply with SFAS
133.  If you believe that the options are not subject to SFAS 133,
please cite the specific literature (by pronouncement and
paragraph)
that supports your accounting.

Note 1 - Summary of Significant Accounting Policies, page F-8

Vendor Concentration, page F-9

7. Please explain to us how you account for vendor volume
discounts,
where you present them on your statements of operations, and tell
us
how both comply with EITF 02-16.

Accrued Expenses, page F-11

8. Please explain to us what "due to insurance companies"
represents
and how you account for it.

Item 9A.  Controls and Procedures, page 55

9. Please tell us the conclusion that your President and Chief
Executive Officer and the Principal Financial Officer reached
about
the effectiveness of your disclosure controls and procedures.  In
addition, please tell us how your disclosures comply with Item 307
of
Regulation S-K.

      Please respond to these comments within 10 business days of
the
date of this letter or tell us when you will provide us with a
response.  Please furnish a letter that keys your responses to our
comments and provides the requested information.  Detailed letters
greatly facilitate our review.  Please file your letter on EDGAR
under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include all information 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 your letter, 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
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Tabatha Akins, Staff Accountant, at (202)
551-
3658 or Oscar Young, Senior Staff Accountant, at (202) 551-3622 if
you have questions regarding the comments.  In this regard, do not
hesitate to contact me, at (202) 551-3679.

								Sincerely,

							Jim B. Rosenberg
Senior Assistant Chief Accountant
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Mr. Daniel R. Ouzts
Medicore, Inc.
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