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      Unassociated Document

    BRT
      REALTY TRUST

    60
      Cutter
      Mill Rd. Suite 303

    Great
      Neck, NY 11021

    (516)
      466-3100

    April
      11,
      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 additional comment letter dated April 4, 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 additional responses
      below to each of your comments. Our responses follow the order of your
      letter.

    1.
      With respect to the statement requested, we acknowledge the
      following:

          ·

            The
              Company is responsible for the adequacy and accuracy of the disclosures
              in
              the filings;

          ·

            Staff
              comments or changes to disclosures in response to staff comments do
              not
              foreclose the Commission from taking any action with respect to the
              filings; and

          ·

            The
              Company may not assert staff comments as a defense in any proceeding
              initiated by the Commission or any person under federal securities
              laws of
              the United States.

    2.
      With respect to the comment regarding our loan portfolio and the individual
      who
      became incapacitated in May 2007 and how we considered paragraphs 8-10 of SFAS
      114 in determining that these loans were not impaired at September 30, 2007
      and
      December 31, 2007, please be advised:

    We
      review
      our loan portfolio each quarter for possible impairment. The loans made to
      the
      entities controlled by this individual were discussed and reviewed as part
      of
      our normal quarterly review procedures. This individual had in place prior
      to
      the event which resulted in his incapacitation, a capable management team,
      which
      had been managing these properties, as well as other properties owned by this
      individual, both before and after his incapacity. Since this individual has
      become incapacitated, we have been monitoring the situation and are in close,
      regular contact with his management group. All of these loans (except for a
      single loan in the amount of $2,700,000) are collateralized by income producing
      multi-family rental properties; have a floating rate of interest ranging from
      prime plus 4% to prime plus 5% with minimum rates of interest ranging from
      12.75% to 13.25% and have maturity dates ranging from February 8, 2008 to August
      10, 2008. In accordance with paragraphs 8-10 of SFAS 114, impairment is
      recognized when based on current information and events, it is probable that
      we
      will not be able to collect all amounts due according to the contractual terms
      of the loan agreement. All of these loans are collateral dependent and we
      anticipate payment of principal and interest from the current cash flow and
      the
      sale of the collateral. Additionally, the payment history demonstrated by the
      borrowing entities since the principal’s incapacitation make it probable that we
      will be able to collect all amounts contractually due. Based on these
      considerations we determined that these loans were not impaired at September
      30,
      2007.

    For
      the
      quarter ended December 31, 2007, we performed our normal quarterly review of
      the
      loans and determined that no impairment existed at December 31, 2007.
      Additionally, before the filing of our December 31, 2007 Quarterly Report on
      Form 10-Q, our representative performed a site inspection of each of the
      properties securing our loans. From the time of the incapacitation through
      the
      filing of our Annual Report on Form 10-K and as of December 31, 2007, all of
      the
      loans made to this individual’s entities, with the exception of the single loan
      in the amount of $ 2,700,000, had performed according to their contractual
      terms

    The
      single loan in the amount of $2,700,000, which is secured by a single family
      residential property located in Westchester County, New York, was reclassified
      as non-performing as of December 31, 2007, but no impairment charge was taken
      as
      we have determined based on our quarterly loan impairment analysis that the
      estimated collateral value is sufficient to collect all amounts due.

    We
      continue to monitor the loans as part of our quarterly review process and if
      conditions and events change, will record impairment charges should it be
      probable that that we will not be able to collect all amounts due.

    3.
      You have asked us to clarify how we considered the criteria in paragraph 5
      (c)
      of FIN 46(R) in determining that the joint venture was not a variable interest
      entity. Specifically, you have asked us to clarify whether or not the registrant
      is the investor with disproportionately few voting rights and if it is, clarify
      how we determined that substantially all the joint venture’s activities did not
      involve and were not conducted on the registrant’s behalf.

    Paragraph
      5(c)(ii) of FIN46(R) states that one of the criteria that subject an entity
      to
      consolidation is that substantially all the activities either involve or are
      conducted on behalf of the investor that has disproportionately few voting
      rights.

    This
      joint venture is capitalized 25% by a wholly-owned subsidiary of the registrant
      and 75% by a subsidiary of CIT Capital USA. Although we hold a minority of
      the
      equity interest in this joint venture, pursuant to the joint venture agreement,
      all major decisions regarding this joint venture require the approval of both
      members resulting in the registrant effectively holding 50% of the voting rights
      and CIT Capital USA effectively holding 50% of the voting rights. Given these
      facts, the CIT entity, not the registrant, is the investor with
      disproportionately few voting rights.

    In
      addition, both BRT and CIT Capital USA are involved in the real estate lending
      business and the joint ventures activities are not conducted on behalf of the
      CIT member which has the disproportionately few voting rights but is conducted
      for the benefit of both members of the joint venture.

    If
      there
      are any additional questions or comments that you may have, please contact
      me at
      the number listed above.

    Sincerely,

    BRT
      REALTY TRUST

    /s/George
      Zweier

    George
      Zweier

    Vice
      President and

    Chief
      Financial Officer