SecProbe.io

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      Mail Stop 7010

      November 9, 2005

Mr. Domenico Cecere
KB Home
10990 Wilshire Boulevard
Los Angeles, California 90024

	Re:	KB Home
		Form 10-K for Fiscal Year Ended November 30, 2004
		Form 10-Q for Fiscal Quarter Ended August 31, 2005
      File No. 1-09195

Dear Mr. Cecere:

      We have limited our review of your filing to those issues we
have addressed in our 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.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may 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.

FORM 10-K FOR THE YEAR ENDED NOVEMBER 30, 2004

Note 5 - Consolidation of Variable Interest Entities

1. We acknowledge that we have previously requested information
about
this subject.  Since you have had more time to apply this
guidance,
we have further comments.  Please provide for us a more
comprehensive
analysis of how you have applied FIN 46(R) regarding your land
option
contracts.  In particular:

* Provide a description of how your various option contracts are
structured;

* Tell us how you define whether a land option contract is a VIE;

* Provide an example of a land option contract (if determined to
be a
VIE) requiring consolidation and one not requiring consolidation,
with emphasis on the various distinguishing elements.

Please accompany your analysis with direct reference to the
accounting guidance and/or details concerning how you have
interpreted this guidance.

FORM 10-Q FOR THE PERIOD ENDED AUGUST 31, 2005

Note 13 - Subsequent Event

2. We read that you sold substantially all of the assets of your
mortgage banking business to Countrywide and that you concurrently
created a 50/50 joint venture with Countrywide through which loans
will be offered to your homebuyers.  The details and accounting of
this transaction are unclear to us from your current disclosure.
We
have the following comments:

* We read that you "received all cash in exchange for the assets
sold."  Given the formation of the joint venture, we assume that
you
sold to Countrywide for cash 50% of the assets of your mortgage
banking business, and that you contributed the remaining 50% of
the
assets of your mortgage banking business to the new joint venture.
Please confirm our assumption, if true.  If our assumption is
wrong,
please explain this transaction to us in more detail.  Your
response
should specifically address and quantify the assets contributed to
the joint venture by each company.

* Please tell us how you accounted for this transaction and the
guidance that you relied upon.  Your response should specifically
address and quantify any gain or loss recorded on this transaction
and how it was calculated.

* We read that this transaction is based upon an agreement with
Countrywide dated June 30, 2005.  Please provide us with a copy of
that agreement.  Also, tell us how you determined that this
agreement
did not need to be filed as a material agreement, given that your
mortgage banking business is one of your two reportable segments.

*	*	*

		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a response letter that keys your responses to our comments
and provides any requested information.  Detailed 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 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 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 their 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 regarding these comments, please
direct them to Jennifer Thompson, Staff Accountant, at (202) 551-
3737
or, in her absence, to John Hartz, Senior Assistant Chief
Accountant,
at (202) 551-3689 or the undersigned at (202) 551-3768.

      Sincerely,

      John Cash
      Accounting Branch Chief
Mr. Domenico Cecere
KB Home
November 9, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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