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corresp

April 27, 2005

Via Facsimile 202.942.9528

and Via EDGAR

Mr. James Murphy

Division of Corporation Finance

United States Securities and Exchange Commission

450 Fifth Street, N.W., Stop 4-5

Washington, D.C. 20549-0405

    Re:
    Toreador Resources Corporation

Form 10-K, for the year ended December 31, 2004

File No. 0-02517

Dear Mr. Murphy:

     On behalf of Toreador Resources Corporation (the “Company”), we are submitting the Company’s
responses to the engineering comments to the Company’s Form 10-K for the year-ended December 31,
2004 (the “Form 10-K”) set forth in the letter from the Securities and Exchange Commission (“SEC”)
dated April 19, 2005. Please be advised that separately we will be responding to the accounting
comments to the Form 10-K set forth in the letter from the SEC dated April 15, 2005.

     The staff’s comments are set forth below and the Company’s responses are set forth after the
staff’s comments.

    1.
    You disclose that 69% of your proved reserves in France and 31% of your proved reserves in
Turkey will not be produced until after the exploitation permits have expired. These
post-expiration volumes represent almost 60% of your total proved reserves. As we indicate on
our website at: www.sec.gov/divisions/corpfin/guidance/cfactfaq.htm it is the staff’s
position that automatic renewal of such agreements cannot be expected if the regulatory body
has the authority to end the agreement unless there is a long and clear track record which
supports the conclusion that such approvals and renewals are a matter of course. Please
revise your document to remove these reserves from the classification of proved reserves until
such time that the contracts have been legally renewed.

    Response: In conjunction with its independent petroleum engineers, LaRoche
Petroleum Consultants, Ltd., the Company determined the proved reserves for its Turkish and
French permits as of December 31, 2004 in accordance with the applicable industry

Mr. James Murphy

April 27, 2005

Page 2

    standards and guidelines. The Company believes that the Turkish and French permits to which
the proved reserves are credited will be renewed as a matter of course pursuant to a long
and clear track record and that proved reserves relating to the post-expiration of the
permit period should, therefore, be included in the Company’s proved reserves totals.

    In order to substantiate this treatment, in the fall of 2001 in connection with a Form S-4
Registration Statement (No. 333-72314), the Company provided the SEC with, among other
items, copies of (i) the legal opinion of the Yazici Law Offices dated November 30, 2001,
and filed as Exhibit 99.3 to the Form S-4 Registration Statement with regard to the Turkish
permits and (ii) a letter from the French Ministry of Economy, Finance and Industry dated
December 3, 2001. Copies of these documents are enclosed herewith. These documents (along
with the correspondence regarding various supporting communications) were provided at such
time to substantiate the fact that as a matter of course and pursuant to a long and clear
track record these permits would be renewed. The permits referenced in the Form 10-K are
the same permits that are the subject of the information provided to the SEC.

    In pertinent part, the Yazici Law Offices legal opinion states: “We are of the opinion that
the petroleum right holders continuing the production of economical quantities of petroleum
and applying the good oil field practice during the conduct of the petroleum operations in
Turkey will automatically be granted with the extension of the lease term at the end of the
initial twenty years.” The Company has verified with the Yazici Law Offices that this legal
opinion continues to be accurate. Based on a review of publications of exploitation permits
in Turkish newspapers and conversations between representatives of the Company and the
General Directorate Petroleum Affairs (the “GDPA”) of Turkey, the Company has learned that
since 1998, there have been at least thirty (30) renewals of exploitation permits, with a
majority of those renewals occurring since 2001. In addition, the GDPA has indicated that
the renewal of an exploitation permit has never been denied.

    The French Ministry of Economy, Finance and Industry verified in the prior correspondence
that is attached hereto that there was no competitive bidding or public scrutiny in
connection with the renewal of these French exploitation permits. Additionally, in
accordance with correspondence provided in 2001, representatives of the Company were advised
by the French Ministry that where financial and technical qualifications have been met by
the applicant, the result would be a renewal of the permit. The Company’s French attorney,
Ran Hamou, has verified that the French Mining Code has not changed since December 3, 2001
with regard to the renewal of the

Mr. James Murphy

April 27, 2005

Page 3

    exploitation permits. He has also verified that the financial and technical qualifications
criteria for the renewal of an exploitation permit are the same as the financial and
technical qualifications criteria for the initial granting of an exploration or exploitation
permit. The Company’s wholly-owned indirect subsidiary, Madison Energy France, has been
operating in France since 1993 and has never been denied the granting of any exploration or
exploitation permit for which it has applied. Since 2001, DHYMA (the French agency in
charge of permits) reports that three (3) exploitation permits have been renewed and that no
requests for the renewal of an exploitation permit have ever been denied.

    Therefore, the Company believes that there is a long and clear track record supporting its
conclusion that the renewal of these permits will be as a matter of course.

    2.
    We note the large positive revision of oil reserves in France in 2002 and we also note that
your oil production rate in France has not significantly changed since 2002. Your reserve
life in France is currently over 27 years. Supplementally, please provide us with the
technical justification for these reserves and the reason that they were increased in 2002.
In addition, please tell us of your plans for increasing production of these reserves and for
developing the remaining proved undeveloped reserves.

    Response: The positive revision of French oil reserves in 2002 was the direct
result of the increase in oil prices from 2001 to 2002. The average price per barrel for
French oil was $29.50 for the 2002 reserve amounts, a 75% increase over the 2001 average
price per barrel of $16.88. The Company’s French reserves are produced at a high lifting
cost. The increased oil price extended the productive life of the assets.

    With regard to the French production, the Company acquired the French reserves on December 31,
2001 through the acquisition of Madison Oil Company. At the time of the acquisition,
Madison Oil Company was party to a credit facility with Barclays Bank PLC (“Barclays”).
Barclays informed the Company within three (3) months after the acquisition of Madison Oil
Company that it was abandoning the reserve-based lending business. Barclays requested that
the Company transfer the credit facility or retire it. The Company continued during this
period in its attempts to restructure this financing in order to commence development of
these reserves. In January 2004, the facility was retired. Until the facility was retired,
Barclays had required that all cash generated from the Company’s foreign operations be used
to repay the facility. Therefore, the Company was unable to drill its French proved
undeveloped reserves until the facility was discharged.

Mr. James Murphy

April 27, 2005

Page 4

    Following the retirement of the Barclays facility, the Company began an aggressive drilling
program in France by spending over $6 million for the drilling of seven new wells and
numerous workovers. French production increased to 106,000 barrels in the fourth quarter of
2004, a 20% increase over the first quarter of 2004. Currently, the Company has $10 million
budgeted for 2005 capital projects in France.

    If you have any comments to our responses, please call me at 214.651.5562.

Very truly yours,

/s/ Janice V. Sharry

Janice V. Sharry

Direct Phone Number: 214.651.5562

Direct Fax Number: 214.200.0620

Janice.Sharry@haynesboone.com

JVS:tk

D-1337531_1.DOC

    cc:
    H. Roger Schwall (202.942.9528)

G. Thomas Graves III

Douglas W. Weir

YAZICI LAW OFFICES

Piyade Sokak No. 18/10

Cankaya 06540 Ankara

Phone : 90 b312 442 5083

Facsimile : 90 312 440 0630

e-mail: mvazici@yazici-hukuk.com.tr

November 30, 2001

Madison Oil Company

9400 North Central Expressway, Suite 1209

Dallas, Texas 75231

Re:     Registration Statement on Form S-4 333-72314

We, the members of Ankara Bar Association acting as the special Turkish counsel to Madison Oil
Company (“Madison”) hereby declare that we have reviewed the section of Amendment No. 3 of Form S-4
(“Amendment No. 3”) of Toreador Resources Corporation entitled “Information About Madison” as it
relates to Madison’s operations in Turkey. In this regard, Madison currently has permits covering
the Zeynel field (the “Zeynel Permit”), the Cendere Field (the “Cendere Permit”), the Thrace Basin
(the “Thrace Permits”) and the Calgan exploration permit (the “Central and SE Exploration
Permits”), the actual permits having been reviewed by us.

The disclosure under “Information About Madison” in Amendment No. 3 concerning the Zeynel
Permit, the Cendere Permit, the Thrace Permits and the Central and SE Exploration Permits (other
than reserve, well, acreage and drilling information relating thereto) contains a description of
all material terms of these permits and is complete and accurate in all material respects as such
information relates to such permits.

The Turkish Petroleum Law dated March 7, 1954 no. 6326 as amended (“Petroleum Law”)
stipulates the rights and obligations of the petroleum right holders who holds either exploration
licenses or exploitation leases to explore, develop and produce hydrocarbons. Madison, with two
different legal entities acting as the petroleum right holder in Turkey both performs exploration
and production activities. The exploration licenses granted for such purpose will have the
exclusive right to convert such license into an exploitation lease in case of an oil discovery.
The exploration License terms are four years with the condition to be extended for two years
twice provided that drilling obligations stipulated in the Petroleum Law is satisfied.

The Exploitation Leases are granted for a period of twenty years. If an exploration license is
extended for development under the Petroleum Law after a discovery on the exploration license, the
term of such extension is credited as a part of the exploitation lease.

Upon application by a petroleum right holder holding an exploitation lease, who has complied
fully with his obligations, the lease may be renewed twice by the decision of the council of
ministers for a additional term not exceeding ten years each time if found in appropriate with the
national interest, technical and economical terms and so proposed by the general directorate of the
petroleum affairs (“GDPA”).

We are in the opinion that the petroleum right holders continuing the production of economical
quantities of petroleum and applying the good oil field practice during the conduct of the
petroleum operations in Turkey will automatically be granted with the extension of the lease
term at the end of the initial twenty years.

The exploitation lease may be revoked in case the petroleum right holder fails to produce
petroleum therefrom in economical quantities within the first year, upon the ninety days
notification from GDPA or in case the petroleum produced in economical quantities during the first
year from the lease ceased thereafter, is not resumed following the ninety days notification from
GDPA. However no notice shall be given before the expiration of three months from the cessation of
production or before the expiration of one year from the cessation of production if exploratory or
development drillings on the lease area being carried out with due diligence.

Any dispute arising from GDPA’s or the council of ministers decision will be settled through
the high administrative court of Council of State.

We hereby also consent to the filing of this opinion as an exhibit to the Registration
Statement on Form S-4 (No. 333-72314) relating to the merger of a wholly-owned subsidiary of
Toreador Resources Corporation with and into Madison Oil Company and to the references to our firm
name in such Registration Statement in the Information About Madison, and the Legal Matters
sections and any summaries of our opinion contained in any such sections.

In giving such consent, we do not admit that we come within the category of persons whose
consent is required under Section 7 of the Securities Act of 1933, as amended, or the rules and
regulations of the Securities Exchange Commission thereunder, nor do we admit that we are experts
with respect to any part of such Registration Statement within the meaning of the term “experts”
as used in the Securities Act of 1933, as amended, or the rules and regulations of the Securities
and Exchange Commission thereunder.

Murat Yazici

Senior Partner Yazici

Law Offices

[Logo French Republic]

Paris 3 December 2001

    DIRECTION GENERALE DE
L’ENERGIE ET DES MATIERES PREMIERES
DIRECTION DES RESSOURCES ENERGETIQUES ET MINERALES

BUREAU 18 — EXOPLORATION — PRODUCTION — DES HYDROCARBURES

41 BOULEVARD VINCENT AURIOL

75703 PARIS CEDEX 13

TELEPHONE/ 01 53 94 14 81

103115-0008

Dear General Director,

As agreed in our telephone conversation of Friday 30 November 2001 with the bureau of
exploration and production of hydrocarbons, you will find attached a document indicating the
conditions upon which, pursuant to the French Mining Code and its application decree, a
hydrocarbons concession can be prolongated.

Best regards,

Olivier Ravel

In charge of the sub-division

of Hydrocarbons Supplying.

MADISON ENERGY France S.C.S.

Monsieur Emmanuel MOUSSET

Directeur Général

13/15 boulevard de la Madeleine

75001 Paris

[Logo Ministry of Economy Finance and Industry]

2/5

Conditions upon which, pursuant to the Mining Code and its application decree, a hydrocarbon
concession can be extended.

(as at December 3,2001)

Mines can onlv operated pursuant to a concession bv a corporation having the technical and
financial capacities. This concession can be extended

Extract of MINING CODE: “............

TITLE 111

Mineral Development

Section 21

(Law No 94-588 dated 15 July 1994, Section 4)

(Law No 98-297 dated 21 April 1998, Section 3)

Subject to the provisions of article 22, mines can only be worked under a concession or
by the State.

In overseas départements, with the exception of liquid or gaseous hydrocarbons, mines can
also be worked under an extraction authorisation or extraction permit granted in the
conditions stipulated in chapter IV of this section.

Section 25

(Law No 94-588 dated 15 July 1994, section 5)

The concession is granted by administrative order of the order of the Council of State
after a public inquiry and competitive bidding subject to application of the provisions of
article 26 and an undertaking to comply with the general conditions. As necessary, the
general conditions shall be supplemented by specific conditions detailed in specifications.
The general and specific conditions are defined by administrative order of the Council of
State and notified beforehand to the bidders.

Nobody can obtain a concession unless in possession of the technical and financial capability
necessary for successful completion of the exploration and needed to meet the obligations
mentioned in articles 79, 79-1 and 9