SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010
								September 15, 2005

Mr. Herbert Kurz
President
Presidential Life Corporation
69 Lydecker Street
Nyack, NY  10960

Re:	Presidential Life Corporation
	Item 4.01 Form 8-K
      Filed September 12, 2005
	File No. 0-05486

Dear Mr. Kurz:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise 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 detailed as necessary in your
explanation.

	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 number listed
at
the end of this letter.

Item 4.01: Changes in Registrant`s Certifying Accountants
1. Please revise the second paragraph of your filing related to
disagreements to cover the interim period from the date of your
last
audited financial statements through the date of dismissal of your
former accountant as required by Item 304(a)(1)(iv) of Regulation
S-
K.
2. Please revise the fifth paragraph of your filing related to
reportable events to cover the interim period from the date of
your
last audited financial statements through the date of dismissal of
your former accountant as required by Item 304(a)(1)(v) of
Regulation
S-K.
3. Please provide your revised disclosure to your former
accountants
and have them provide an updated letter stating whether they agree
with the statements made in your revised Form 8-K.  Please file
this
updated letter as an Exhibit to your amended Form 8-K as required
by
Item 304(a)(3) of Regulation S-K.

       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
respond.
You may wish to provide us with marked copies of the amendment 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 cover letters greatly facilitate
our
review.  Please file the letter on EDGAR under the form type label
CORRESP.  Please understand that we may have additional comments
after reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes 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 writing, 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.

	If you have any questions, please call me at (202) 551-3638.

							Sincerely,

							Mark K. Brunhofer
							Staff Accountant
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Mr. Herbert Kurz
Presidential Life Corporation
September 15, 2005
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