SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

							March 18, 2005

via facsimile and U.S. mail

Mr. Stephen J. Crowe
Vice President, Finance and Chief Financial Officer
ChevronTexaco Corporation
6001 Bollinger Canyon Road
San Ramon, California 94583

	Re:	ChevronTexaco Corporation
		10-K for the fiscal year ended December 31, 2004
		File No. 001-00368

Dear Mr. Watson:

      We have reviewed the above filing and have the following
accounting comments.  Our review has been limited to the areas
identified below, which were communicated to representatives from
your company on March 15, 2005.   Please provide us a response to
the
comments below and include appropriate disclosure in future
filings.
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.  In some of our
comments,
we may ask you to provide us with supplemental information so we
may
better understand your disclosure.  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.

10-K for the year ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page FS-2

	Litigation and Other Contingencies, page FS-15

		Accounting for Buy/Sell Contracts, page FS-17

1. In your disclosure you state: "At issue with the SEC is whether
the industry`s accounting for buy/sell contracts..." which seems
to
imply that all companies in your industry account for these types
of
transactions in the same manner as you.  Please explain to us how
you
came to this conclusion, and if applicable, explain to the reader
that other companies may account for these transactions
differently
than you, and explain the alternative accounting.  Please also
include similar disclosure where applicable throughout the
remainder
of the document.

2. Please identify which operating segments these transactions
relate
to, and provide appropriate quantitative and qualitative
disclosure
in your segment footnote.

3. Please disclose that the nature of these transactions is
fundamentally different in character than the primary operations
for
the segment in which these types of contracts are utilized, or
explain to us why you do not believe these types of transactions
to
be fundamentally different than your primary operations.  Please
also
include similar disclosure where applicable throughout the
remainder
of the document.

General

4. Continue to update your disclosures associated with buy/sell
transactions and suspended well costs in future filings to include
information which FASB and the EITF may release in the future
regarding these matters.

Closing Comments

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your responses to our comments
and
provide any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  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 the 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 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 filings or
in
response to our comments on your filings.

      Direct questions regarding accounting issues and related
disclosures to Mark A. Wojciechowski, at (202) 942-1928 or, in his
absence, to Jenifer C. Gallagher, at (202) 942-1923.  Direct
questions relating to all other disclosure issues to the
undersigned
at (202) 942-1870.  Direct all correspondence to the following ZIP
code: 20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director
??

??

??

??

Mr. Stephen J. Crowe
ChevronTexaco Corporation
March 18, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>