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CORRESP
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corresp

December 9, 2005

United States Securities and Exchange Commission

450 Fifth Street

Washington, D.C. 20549

Attention: John Cash, Accounting Branch Chief

    Re:

    File No. 1-09195

    KB Home

    Form 10-K for Fiscal Year Ended November 30, 2004

    Form 10-Q for Fiscal Quarter Ended August 31, 2005

Dear Mr. Cash:

This letter responds to the comments of the Securities and Exchange Commission (the “Commission”)
staff contained in your letter dated December 1, 2005 regarding the reports listed above filed by
KB Home (the “Company”).

Set forth below are the Commission’s comments, followed by the Company’s responses.

Form 10-Q for the fiscal quarter ended August 31, 2005

Note 13 — Subsequent Event

We note your response to comment 2 from our letter dated November 9, 2005. Please confirm to us in
writing the information that was shared in the November 28, 2005 phone call we had with Bill
Hollinger, your chief accounting officer. Specifically, please tell us the type and amount of
consideration received from Countrywide for the sale of substantially all of the assets of your
mortgage banking business. Also, please tell us in a reasonable level of detail, and quantify, the
assets that Countrywide contributed to the newly formed joint venture, and tell us whether any of
those assets were among the mortgage banking assets that you sold to Countrywide for cash.

Response

On September 1, 2005, the Company received as full consideration for the sale of substantially all
of the assets of its mortgage banking business, $42.4 million in cash from Countrywide Financial
Corporation (“Countrywide”). The sale transaction did not involve any note obligations,
contingencies, earn-outs or future payments.

Separately from the asset sale, on September 1, 2005, the Company and Countrywide also formed the
Countrywide KB Home Loans joint venture to which each company contributed capital of $15 million.
The Company’s capital contribution was comprised solely of cash, while Countrywide’s contribution
was comprised of approximately $12.5 million of cash and $2.5 million of leasehold improvements.
The leasehold improvements contributed by Countrywide relate to two mortgage

operations centers in Las Vegas, Nevada and San Antonio, Texas which the Company leased and used in
connection with its mortgage banking business prior to the asset sale transaction. The leasehold
interests and improvements were sold to Countrywide in the asset sale transaction and are now
solely leased and used by the Countrywide KB Home Loans joint venture. Countrywide contributed the
leasehold improvements to the joint venture at the Company’s book value of the leasehold
improvements prior to the asset sale transaction. Countrywide did not contribute to the
Countrywide KB Home Loans joint venture any other assets, including financial assets, purchased
from the Company in the asset sale transaction.

* * *

The Company acknowledges that (1) the Company is responsible for the adequacy and accuracy of the
disclosure in its filings, (2) staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action with respect to the Company’s
filings, and (3) 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.

The Company sincerely hopes that this letter appropriately responds to each of the staff’s comments
and questions. If you have any further questions or comments, please do not hesitate to contact me
at 310-231-4014 or Bill Hollinger, the Company’s chief accounting officer, at 310-231-4028.

Sincerely,

/s/ Domenico Cecere

Domenico Cecere

Senior Vice President and Chief Financial Officer