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CORRESP
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CORRESP

June 21, 2007

Mr. James Rosenberg

Senior Assistant Chief Accountant

Unites States

Securities and Exchange Commission

Washington, D.C. 20549

Mail Stop 6010

    RE:

    Enzon Pharmaceuticals, Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2006

    Filed March 2, 2007

    File No. 0-12957

Dear Mr. Rosenberg:

By letter dated June 12, 2007 from the Staff of the Commission, the Staff provided certain comments
regarding the Form 10-K for the Fiscal Year Ended December 31, 2006 (the “Form 10-K”) of Enzon
Pharmaceuticals, Inc. (the “Company”) filed on March 2, 2007. Enclosed please find the response to
your comment letter in the following numbered paragraphs which correspond to the paragraph numbers
in the comment letter.

    1.

    You indicate that you engaged an independent valuation specialist to assist
management in its determination of the fair value of the Abelcet asset group and to test
for impairment. This reference suggests to an investor that you are placing reliance on
the firm, which the staff believes requires the firm be named in a ’34 Act filing.
Additionally, if the Form 10-K is incorporated by reference into a ’33 Act registration
statement, a consent from the valuation specialist must be provided in the ’33 Act
registration statement. Please advise.

Response:

We have the agreement of Duff & Phelps, LLC to provide their non-expert consent to be named in our
proposed filing of a Form 8-K that will include disclosure naming the independent valuation firm
and attaching their consent in the form of Exhibit 99.1 to being named in that Form 8-K, and by
reference in the current ’33 Act registration statements (Nos. 333-101898, 333-64110, 333-18051,
333-121468, 333-140282, 333-134453, 333-132467, and 333-137723), collectively the “’33 Act
Registration Statements”.

To respond to this comment, we propose to file a Form 8-K that will (1) include disclosure naming
the independent valuation firm referred to in our Form 10-K and (2) attach the non-expert consent
of the independent valuation firm to being named in that Form 8-K and incorporated by reference
into each of our ’33 Act Registration Statements.

Please note that each of our ’33 Act Registration Statements were filed with the Commission and
declared effective prior to the filing of our Form 10-K for the fiscal year ended December 31,
2006. Therefore, we would not have been required to file the consent of Duff & Phelps, LLC with
those registration statements at the time those registration statements were filed.

Because we do not believe we are required to amend our Form 10-K for the fiscal year ended
December 31, 2006 in response to comments 2 and 3 below, we would propose to disclose the required
information and non-expert consent in a Form 8-K filed now.

    2.

    Please provide us, in disclosure-type format, a roll forward of each item that
reduces your gross revenue for the periods presented showing the following:

    •

    Beginning balance,

    •

    Current provision related to sales made in the current period,

    •

    Current provision related to sales made in prior periods,

    •

    Actual returns or credits in current period related to sales made in current
period,

    •

    Actual returns or credit in current period related to sales made in prior
periods, and

    •

    Ending balance.

Response:

The schedule below shows the roll forward of each of our gross to net sales deductions for the six
months ended December 31, 2005 as well as for the twelve months ended December 31, 2006.

Gross-to-Net Sales Adjustments

(in thousands)

    Other

    Medicaid

    Cash

    (including

    Medicaid

    Administrative

    Chargebacks (1)

    Discounts (1)

    returns)(1)

    Rebates (2)

    Fees (2)

    Total

    Balance at June 30, 2005

    $
    6,137

    $
    265

    $
    840

    $
    2,604

    $
    347

    $
    10,193

    Provision related to sales made in
current period

    13,161

    717

    2,863

    448

    537

    17,726

    Provision related to sales made in
prior periods

    —

    —

    —

    —

    —

    —

    Returns and
credits (3)

    (15,581
    )

    (780
    )

    (2,399
    )

    (1,220
    )

    (598
    )

    (20,578
    )

    Balance at December 31, 2005

    3,717

    202

    1,304

    1,832

    286

    7,341

    Provision related to sales made in
current period

    26,363

    1,607

    5,238

    2,614

    650

    36,472

    Provision related to sales made in
prior periods

    (79
    )

    (9
    )

    (1
    )

    112

    (3
    )

    20

    Returns and
credits (3)

    (26,613
    )

    (1,632
    )

    (4,774
    )

    (3,223
    )

    (728
    )

    (36,970
    )

    Balance at December 31, 2006

    $
    3,388

    $
    168

    $
    1,767

    $
    1,335

    $
    205

    $
    6,863

    (1)

    Included as a reduction in accounts receivable

    (2)

    Included as an accrued liability

    (3)

    Relate to sales made in the current period

Of the sales accruals and provisions, greater than 90% relate to Abelcet. Should our Products
Segment continue to grow, this might not be true in the future. We would therefore propose that
beginning with our next annual report and for each annual report thereafter, that we include the
above disclosure as part of our Management’s Discussion and Analysis.

    3.

    Your Schedule II should depict the balance and activity in your allowance for
doubtful accounts separately from that of chargebacks, returns and cash discounts. Please
provide us, in disclosure-type format, a revised schedule.

Response:

We considered disclosing the movements in our allowance for doubtful accounts separately during the
preparation of our annual report. However, we believe that both the additions and deductions to the
allowance for doubtful accounts have been immaterial in the periods presented. As demonstrated
below, the movements in our allowance for doubtful accounts have been less than 1% when compared to
the same activity for chargebacks, returns and cash discounts. If the movements in our allowance
for doubtful accounts become material in the future, we would propose that we would disclose it
separately at that point in Schedule II.

As requested, we have revised Schedule II below to show the balance as well as the activity in our
allowance for doubtful accounts separately.

Schedule II — Valuation and Qualifying Accounts

(In thousands)

    Additions

    Balance at

    Charged to

    Balance

    beginning

    costs and

    Charged to

    at end of

    of period

    expenses

    other accounts

    Deductions

    period

    Year ended December 31, 2006:

    Allowance for chargebacks,
returns and cash discounts

    $
    5,152

    —

    $
    30,859

    $
    (30,933
    )

    $
    5,078

    Allowance for doubtful accounts

    $
    71

    $
    245

    —

    $
    (71
    )

    $
    245

    Six months ended December 31, 2005:

    Allowance for chargebacks,
returns and cash discounts

    $
    7,242

    —

    $
    14,943

    $
    (17,033
    )

    $
    5,152

    Allowance for doubtful accounts

    —

    $
    71

    —

    —

    $
    71

    Year ended June 30, 2005:

    Allowance
for chargebacks, returns and cash discounts

    $
    8,785

    —

    $
    37,982

    $
    (39,525
    )

    $
    7,242

    Allowance for doubtful accounts

    —

    —

    —

    —

    —

    Year ended June 30, 2004:

    Allowance for chargebacks,
returns and cash discounts

    $
    7,134

    —

    $
    52,619

    $
    (50,968
    )

    $
    8,785

    Allowance for doubtful accounts

    —

    —

    —

    —

    —

The Company acknowledges 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.

If I can be of any further assistance, please do not hesitate to contact me at (908) 541-8759.

    Very truly yours,

    /s/ Craig A. Tooman

    Craig A. Tooman

    EVP Finance and CFO