SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>az04cor1.txt
<DESCRIPTION>CORRESPONDENCE
<TEXT>
                        HOLLYER BRADY BARRETT & HINES LLP
                                551 Fifth Avenue
                               New York, NY 10176

                               Tel: (212) 818-1110
                               FAX: (212) 818-0494

                                    BY EDGAR

                                                     October 21, 2004

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

         Attention: Mr. John Ganley
         Investment Management Division
         Re: Tax-Free Trust of Arizona (33-1857 and 811-4503)

     Dear Mr. Ganley:

     In August 2004 we filed post-effective amendments for Tax-Free Trust of
Arizona (33-1857 and 811-4503) to become effective under Rule 485(a) on October
31, 2004.

     You have provided us three staff comments on the filing, which we address
as follows:

     1. The staff noted that the parent company of the Trust's Sub-Adviser, Banc
One Corporation, merged in June, 2004 with JP Morgan Chase. The staff questioned
whether the transaction resulted in an assignment of the sub-advisory contract
that should have been approved by the shareholders of the Trust.

     No assignment of the sub-advisory agreement within the meaning of Section
2(a)(4) of the Investment Company Act of 1940 occurred. The Sub-Adviser and its
parent company rely on the no action letter "Dean Witter, Discover & Co" (April
18, 1997) 97 CCH Dec. FSLR paragraph 77,354.

     In that case two widely held public companies merged. Neither had any
"controlling" shareholders. Their respective investment advisory subsidiaries
continued as separate entities, performing the same functions with the same
personnel. The staff agreed that the transaction did not constitute an
assignment of the advisory contracts of the subsidiaries within the meaning of
Section 2(a)(4).

     The facts in the case of Tax-Free Trust of Arizona are essentially the
same. Banc One and JP Morgan Chase are widely held public companies with no
"controlling" shareholders. The Sub-Adviser, Banc One Investment Advisors
Corporation, continued after the merger as a separate entity, with the same
personnel, performing the same functions. The portfolio manager, who supervised
the portfolio of Tax-Free Trust of Arizona, remained in place with no change in
duties.

     We believe that for the same reasons as in Dean Witter, there was no
assignment of the Sub-Advisory Agreement in this case. We believe that the Dean
Witter case has been used as precedent in many other similar situations.

     Accordingly, we think that the disclosure in the filing for Tax-Free Trust
of Arizona is appropriate.

     2. The staff noted that under the caption "Brokerage Allocation and Other
Practices" there was language that is no longer appropriate in the light of the
new Rule 12(b)(1)(h) which became effective October 14, 2004. We have deleted
the language noted by the staff.

     3. The staff noted that the language under the considerations by the Board
of Trustees for renewal of the advisory and sub-advisory agreements should be
augmented. We have added additional material and believe that the revised
language meets the requirements of Item 12 (b)(10) of Form N1-A.

     The staff is further advised that the Trust will not assert as a defense in
any action or proceeding by the Commission the fact that staff comments have
been received with respect to this filing or that the Trust has attempted to
respond to such comments.

     Please call the undersigned if you have any questions. As indicated, we
will file an amendment pursuant to Rule 485(b) to be come effective on October
31, 2004, which will supersede the filing under Rule 485(a), which will not
become effective.

                                     Yours sincerely,

                                     /s/ W.L.D. Barrett
                                     Partner

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