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      Unassociated Document

    BRT
      REALTY TRUST

    60
      Cutter
      Mill Rd. Suite 303

    Great
      Neck, NY 11021

    (516)
      466-3100

    March
      27,
      2008

    Ms.
      Linda
      Van Doorn

    Senior
      Assistant Chief Accountant

    United
      States Securities and Exchange Commission

    Division
      of Corporate Finance

    Washington,
      DC 20549

    Dear
      Ms.
      Van Doorn:

    We
      are in
      receipt of your comment letter dated March 6, 2008 regarding our Annual Report
      on Form 10-K for the year ended September 30, 2007 (File No. 001-07172). We
      have
      reviewed your comments and provide responses below to each of your comments.
      Our
      responses follow the order of your letter.

    1.
      With respect to six outstanding loans with an aggregate principal amount of
      $64
      million to six borrowing entities controlled by one individual, you have
      requested that we clarify the number and principal balance of these loans that
      are performing and the number and principal balance that are
      impaired.

    At
      September 30, 2007 and up to the filing date of the Form 10-K, all of these
      loans were performing in accordance with their contractual obligations and
      were
      not impaired. These loans are not the loans described in the second paragraph
      on
      page F-13.

    The
      disclosure in the section “Our Loan Portfolio” was provided to describe the
      credit concentration to borrowers controlled by one individual. To the extent
      that all of the loans were performing, additional information would not provide
      significant additional value to a reader. Nevertheless, in future filings we
      will add the status of the loans to this disclosure.

    2.
      With respect to the trends noted and the current interest rate and credit
      markets, you have asked us to clarify what consideration we gave to discussing
      in the Management’s Discussion and Analysis, the unfavorable trends and effect
      on future operating results including expected increases in the loan loss
      provision referring to Item 303(a)(3)(ii) of Regulation
      S-K.

    In
      drafting Management’s Discussion and Analysis for the Form 10-K, we were
      cognizant of Item 303(a)(3)(ii) of Regulation S-K, which provides for the
      description of “any known trends or uncertainties that the registrant reasonably
      expects will have a material favorable or unfavorable impact on net sales,
      revenues or income from continuing operations.” We refer you to the subheading
“Outlook” under Item 7, Management’s Discussion and Analysis of Financial
      Condition and Results of Operations on page 30 of the Form 10-K. The “Outlook”
section states that a difficult or declining real estate market in the New
      York
      metropolitan area, in the states of Tennessee and Florida, or in other parts
      of
      the country, and a recessionary economy could potentially have the following
      adverse affects on our business: (i) an increase in loan defaults which will
      result in decreased interest and fees on our outstanding real estate loans;
      (ii)
      an increase in loan loss reserves; (iii) an increase in expenses incurred in
      foreclosures and restructurings; (iv) a decrease in loan originations; (v)
      a
      decrease in rental income from properties owned by us or joint ventures in
      which
      we are a venture participant; and (vi) an increase in operating expenses
      relating to real estate properties. The “Outlook” section goes on to state that
      as a result of the more difficult real estate environment (particularly in
      the
      State of Florida) and the disruptions in the credit markets in the second half
      of 2007, we experienced an increase in loan defaults, an increase in loan loss
      reserves, an increase in foreclosure actions and the expenses related to such
      actions and a decrease in loan originations and that we cannot project, if
      and
      when these trends will stabilize or reverse. This disclosure was intended to
      be,
      and we believe it is, responsive to the requirements of Item 303(a) (3) (ii)
      of
      Regulation S-K.

    We
      also
      point out that certain of the Risk Factors included in the Form 10-K contain
      disclosure about trends in our business and note the following:

              ·

              On
                pages 10 and 11 of the Form 10-K under the sub-caption “If borrowers
                default on loans, we will experience a decrease in income and any
                recovery
                may be limited by the value of the underlying property”, after disclosing
                the difficulties in our business commencing in the third quarter
                of fiscal
                2007 (page 11), we state in the last sentence of this risk factor
                as
                follows: “If uncertainty in the mortgage industry continues, we may
                continue to experience defaults by our
                borrowers.”

              ·

              Under
                the heading “Decrease in Loan Originations 2007 Fiscal Year compared to
                the 2006 Fiscal Year” on page 11 of the Form 10-K,” we state as follows in
                the last sentence under this heading: “Unless there are positive changes
                in the environment for real estate transactions and in the credit
                markets,
                the level of originations may decrease in fiscal 2008 as compared
                to 2007,
                which could have an effect on our revenues and net
                income.”

              ·

              Under
                the heading “Our allowance for loan losses and valuation allowances
                against owned real estate may not be adequate to cover actual losses,” on
                page 12 of the Form 10-K, it is stated in the final two sentences
                under
                this heading as follows: “Our allowance for loan losses and impairment
                allowance may not be adequate to cover actual losses and we may need
                to
                take additional reserves in the future. Actual losses and additional
                reserves in the future could materially and adversely affect our
                business,
                net income, shareholders’ equity and cash distributions to our
                shareholders.”

              ·

              Under
                the heading “Dependence on Two Borrowers in Fiscal 2007” on page 13, in
                referring to the significant originations attributable in 2007 to
                two
                borrowers, it is stated as follows in the last sentence under this
                heading: “A significant reduction in our originations, as a result of a
                loss of the business of these two individuals, or either of them,
                without
                replacing them, could have an adverse affect on our revenues and
                net
                income in fiscal 2008.”

    The
      discussion in the “Outlook” section of our Management’s Discussion and Analysis,
      standing alone, and the totality of the information included throughout the
      relevant sections of the Form 10-K, provides appropriate, complete and accurate
      information relating to the trends and effect on operating results related
      to
      the trends noted in your comment letter. In considering the information included
      in the Form 10-K, we concluded that including language in the MD&A that
      merely repeated information appearing elsewhere in the filing, particularly
      in
      the risk factors section, would be redundant. However, we will seek to include
      information in the MD&A section of future filings that will review the
      effect of the current real estate market and any trends relating to the real
      estate credit markets that will have an effect on the company’s results of
      operations.

    3.
      Your comment inquires as to what consideration we gave to Item 3(a)(4) of
      Regulation S-K with respect to disclosing the off balance sheet risk associated
      with our investment in CIT, including reimbursing up to 75% of its foreclosure
      losses, as well as the possibility of having to consolidate CIT under FIN 46
      (R).

    In
      Item
      1. Business under the heading “Joint Venture with CIT Capital USA, Inc.”, (page
      8) we disclosed the following:

    “Losses.
      If the
      joint venture sustains any loss of principal with respect to loans that are
      foreclosed upon, the BRT member will reimburse the CIT member up to 75% of
      the
      actual loss, but
      only to the extent that amounts received by BRT member from cash distributions
      exceed the BRT member’s 9% return, with such reimbursement to be capped at
      two-thirds of 1% of the highest aggregate principal amount of the venture’s
      loans outstanding.” (Emphasis
      added).

    In
      view
      of the provisions of the joint venture agreement, capping the reimbursement
      of
      losses at two-thirds of 1% of the highest aggregate principal amount of the
      venture’s loans outstanding, and requiring such reimbursement only from the BRT
      members distributions in excess of a 9% return, the current risk of
      reimbursement would be approximately $322,000, based on the current outstanding
      portfolio of $48,230,000. Additionally, this reimbursement would first be used
      to reduce the income allocated to the BRT member. Accordingly, this off balance
      sheet risk is both remote and minimal and we do not believe information relating
      to the value of such risk would be meaningful to an investor.

    In
      future
      filings we will expand the disclosure to quantify this risk if it is material
      and if there is a situation where this provision of the joint venture agreement
      is reasonably likely to have a current or future effect on our financial
      condition, changes in financial condition, results of operations or
      liquidity.

    Your
      comment also inquires as to the possibility of having to consolidate the joint
      venture under FIN 46 (R). Please refer to our answer to comment 10
      below.

    4.
      The comment requests a clarification as to why the valuation allowance on
      performing impaired loans would not be adjusted to reflect any changes to the
      impairment measurement as defined in paragraph 13 of SFAS
      114.

    Our
      disclosure in the first paragraph under the sub heading “Income Recognition” in
      Note 1 on page F-8 as it relates to leaving the valuation constant, refers
      only to the addition of accrued interest
      to the
      recorded investment offset by the subsequent cash receipt.

    It
      is our
      policy to review all loans and assets for impairment on a quarterly basis.
      This
      includes loans that have had previous impairment charges.

    Our
      policy as it relates to valuation allowances is discussed more fully in various
      sections of the Report.

    All
      of
      our loans are collateral dependent loans and impairment is based upon the fair
      value of the collateral as discussed in SFAS 114. On page 31 of our Form 10-K
      we
      state that we review our mortgage portfolio and the real estate assets
      underlying our portfolio quarterly to ascertain if there has been any impairment
      in the value of these assets in order to determine if there is a need for a
      provision for an allowance for possible losses. As discussed on page F-9, our
      accounting policy for allowance for possible losses is as stated
      below:

    “A
      loan
      evaluated for impairment is deemed to be impaired when based on current
      information and events it is probable that the Trust will not be able to collect
      all amounts due according to the contractual terms of the loan agreement. When
      making this evaluation numerous factors are considered, including, market
      evaluations of the underlying collateral, estimated operating cash flow from
      the
      property during the projected holding period, and estimated sales value computed
      by applying an estimated capitalization rate to the projected stabilized net
      operating income of the specific property, less selling costs, discounted at
      market discount rates. If upon completion of the valuations, the value of the
      underlying collateral securing the loan is less than the recorded investment
      in
      the loan, an allowance is created with a corresponding charge to
      expense.”

    In
      future
      filings we will modify this disclosure under the income recognition paragraph
      to
      remove any ambiguity that we do not modify our valuation allowance should
      further impairment charges be necessary.

        5.
          The
          comment inquires as to the nature of foreclosure costs and our basis in
          GAAP for
          capitalizing these costs as referenced in the Notes to the Financial Statements
          under the section “Real Estate Properties and Real Estate Properties Held for
          Sale” on page F-9.

    We
      account for direct foreclosure costs such as legal and professional fees, in
      accordance with paragraph 38 of SFAS 15, “Accounting by Debtors and Creditors
      for Troubled Debt Restructurings” and accordingly these costs are expensed as
      incurred.

    During
      the current fiscal year we capitalized approximately $132,000 of costs incurred
      for transfer taxes, title insurance and sheriff charges ($0 and $8,000 in fiscal
      2006 and 2005, respectively). We had considered these costs to be subsequent
      to
      the foreclosure of the property and in accordance with paragraph 29 of SFAS
      15
      we capitalized theses costs. The amount for 2007, as with prior years, are
      immaterial to the results of operations of the company. Upon further review
      these costs may be considered direct foreclosure costs and should have been
      expensed. In the future we will expense such costs.

    In
      future
      filings we will modify our disclosure to state that all expenses incurred in
      the
      connection with the foreclosure of a property will be expensed as incurred
      in
      accordance with SFAS 15 (as amended).

    6.
      The comment requests that we clarify what is meant by the term “represented” as
      it relates to three non-performing loans totaling $37,847,000 in the second
      paragraph on page F-13.

    In
      the
      sentence the phrase “represented by existing multi-family condominium
      developments” denotes that the three non-performing loans are secured by
      existing multi-family condominium developments. In future filings, we will
      change the language from “represented” to “secured by,” as it provides a better
      depiction of the secured nature of the loans.

    You
      have also requested that we clarify and provide further detail in connection
      with the five loans in the aggregate amount of $52,548,000 that were added
      to
      non-performing status at September 30, 2007.

    The
      requested data is presented below.

                Loan

                Designation

                Apopka,FL

                Miami
                  Beach, FL

                Naples,
                  FL

                Fort
                  Wayne, IN

                New
                  York, NY

                Principal
                  Balance

                $19,422,000

                $