SecProbe.io

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<FILENAME>filename1.txt
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      July 25, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX 1-317-685-1588

Mr. David F. White
Chief Financial Officer
Century Realty Trust
823 Chamber of Commerce Building
Indianapolis, Indiana 46204

RE:	Century Realty Trust
Form 10-KSB for the year ended December 31, 2004
Form 10-QSB for the quarter ended March 31, 2005
            File no. 0-7716

Dear Mr. White:

We have reviewed the above referenced filings and have the
following
comments.  We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents.  In our comments, we may 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 or may not 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 on 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 fiscal year ended December 31, 2004

Item 6. Selected Financial Data, page 4

1. Please advise us how your presentation of FFO satisfies all of
the
provisions of Item 10(e) of Regulation S-K, which includes, but is
not limited to, a statement disclosing how the Company`s
management
uses this measure and why they believe it provides useful
information
to investors regarding your financial condition and the results of
operations.  Further, tell us your basis for adding back
unamortized
loan costs written off as this appears to be a recurring item not
within the NAREIT definition of FFO.  Provide us your proposed
disclosures to demonstrate that you will fully comply with all of
the
provisions of Item 10 (e) of Regulation S-K or remove the
reference
to such measure in future filings.

Note 4., Real Estate Held for Sale and Discontinued Operations,
page
22

2. We note that you entered into contracts with separate unrelated
parties to sell the Fox Run Apartments and a restaurant property
in
2004.   We also note that there are a number of contingencies to
be
resolved before the sales are consummated in 2005.  Tell us what
these contingencies are, and how you considered paragraph 30 (b)
of
FAS 144.

*    *    *    *
As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
file your response on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require for an
informed 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
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure 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 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 filings or in response
to
our comments on your filings.

You may contact Kelly McCusker, Staff Accountant, at (202) 551-
3433
or the undersigned at (202) 551-3413 if you have questions.

						Sincerely,

      Cicely D. Luckey
      Branch Chief

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Mr. White
Century Realty Trust
July 25, 2005
Page 1

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