SecProbe.io

Mail Stop 4561         March 6, 2008  VIA USMAIL and FAX (516) 773-2770  Mr. George Zweier Vice President and Chief Financial Officer BRT Realty Trust 60 Cutter Mill Road Great Neck, New York 11021

Re: BRT Realty Trust
 Form 10-K as of September 30, 2007
Filed December 14, 2007
 File No. 001-07172

Dear Mr. George Zweier:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is 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.
 FORM 10-K FOR THE YEAR ENDED SEPTEMBER 30, 2007

Item 1. Business

Our Loan Portfolio, page 4
1. For the six outstanding loans with an aggregate principal amount of $64 million to
six borrowing entities controlled by on e individual, clarify the number and
principal balance of these loans that ar e performing and the number and principal
balance of these loans that are impaired.   For the impaired loans, clarify how this

George Zweier
BRT Realty Trust
March 6, 2008 Page 2
information correlates with the information related to impaired loans disclosed in the second paragraph on page F-13.

Item 7.  Management’s Discussion and Analys is of Financial Condition and Results of
Operations
2. We note the following trends during 2007:

• For fiscal year ended Septembe r 30, 2007, mortgage loans not earning
interest represented approximately  25.5% of your outstanding loan
portfolio and approximately 19.4% of your total assets, but only
approximately 0.5% and approximately  0.4% for the corresponding prior
year ended September 30, 2006.  Refer to page 1.
• You recorded a provision for loan lo ss of $9.3 million for the fiscal year
ended September 30, 2007, while no such provision was taken in prior
years.
• Your loan originations have declined because borrowers who typically make use of your short-term lending have limited or ceased its real estate activities.   Refer to page 2.
• 51% of your loans originated in fiscal year 2007 were to borrowing
entities controlled by one individua l who became incap acitated in May
2007.    A Court appointed guardian is  in the process of beginning an
orderly sale of the assets securing your loans.   Refer to page 4.

Given the above as well as the current interest rate and credit environment, please clarify to us what consideration you gave to discussing in Management’s
Discussion and Analysis the unfavorable trends and effect on future operating
results including expected increases in loan loss provision.   Refer to Item
303(a)(3)(ii) of Regulation S-K.
3. Tell us what consideration you gave to disclosing the off balance sheet risks
associated with your investment in CI T including reimbursing CIT for up to 75%
of its foreclosure losses as well as the possibility of having to consolidate CIT
under FIN46(R). Refer to Item 303(a)(4) of Regulation S-X.

Financial Statements and Notes

Note 1 – Organization, Background a nd Significant Accounting Policies

Income Recognition, page F-8
4. In describing how the company accrues interest income on performing impaired
loans, you have indicated that the valu ation allowance on such loans remains
constant through the life of the loan. Please clarify to us why the valuation

George Zweier
BRT Realty Trust
March 6, 2008 Page 3
allowance would not be adjusted to re flect any changes to the impairment
measurement as defined in  paragraph 13 of SFAS 114.

Real Estate Properties and Real Estate  Properties Held for Sale, page F-9

5. The note indicates that costs incurred in connection with the foreclosure of the
properties collateralizing your real estate loans are capitalized.  Please tell us the
nature of these foreclosure costs and your basis in GAAP for capitalizing these
costs.

Note 2 Real Estate Loans, page F-12
 6. Refer to the second paragraph on page F-13.  The note indicates that three of the
loans that were reclassified to non-performing at September 30, 2007 were represented by existing multi-family condom inium developments in Florida and
that the aggregate principal balan ce of these loans totaled $37,847,000. Please
clarify what is meant by the term represented.  For each of the loans comprising the $52,548,000 balance clarify the following, preferably in tabular format:

• The principal balance and accrued interest balance of each loan;
• Whether there are cross default or cross collateral provisions;
• Whether the loan is secured or uns ecured; if secured describe the
collateral;
• Whether the loan is recourse or  non-recourse to the borrower;
• Whether the loan is considered to be impaired and if so, the amount of the
impairment and related reserve fo r losses established for the loan;
• Whether the loan was considered to be collateral dependent and if so
clarify that the loan loss reserve was determined based on the fair value of the underlying collateral.

7. Show us how you plan to expand your disc losure to better describe your risk
exposure to the loans desc ribed above and to include  the information outlined
above.
 8. Tell us what consideration you gave to di sclosing the amount of interest income
recognized on the cash basis for the impaired loans during the period or if no such cash payments were received, disclosing th at fact. Refer to paragraph 20(c) of
SFAS 114.

George Zweier
BRT Realty Trust
March 6, 2008 Page 4  Note 4 – Investments In Unconso lidated Joint Ventures At Equity

 BRT Funding LLC, page F-15

 9. We note you have provided a broader discussion of the terms of your joint venture
with CIT Capital USA, Inc. on pages 7 - 8.   In future filings please expand your note disclosures to include similar inform ation as discussed in the referenced
section.
 10. As disclosed on page 8, if the joint venture sustains any loss of principal with respect to loans that are foreclosed upon, you reimburse the CIT member up to
75% of the actual loss.   Your protecti on of the CIT member from suffering losses
appears to create a variable  interest.    Tell us how you considered paragraph 5,
14, and 15 of FIN 46(R) in determining that the joint venture did not represent a variable interest enti ty where you are the primary beneficiary.
 Certifications

 11. We note that the identification of the certi fying individual at the beginning of the
certification required by Exchange Act Rule  13a-14(a) also includes the title of
the certifying individual.  Considering that  the certifications must be signed in a
personal capacity, please confirm to us  that your officers signed such
certifications in a personal capacity and that you will revise your certifications in future filings to exclude the title of the certifying individual from the opening sentence.

*   *   *   *

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.    We urge all persons who are responsi ble for the accuracy an d 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 th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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

George Zweier
BRT Realty Trust  March 6, 2008 Page 5  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 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.     You may contact Jaime G. John at (202)  551-3446 or me at (202) 551-3498 if you
have questions.
Sincerely,

   Linda Van Doorn Senior Assistant Chief Accountant