SecProbe.io

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Mail Stop 0510
March 16, 2005

By U.S. mail and facsimile to (276)629-5114

Mr. Douglas I. Payne
Chief Financial Officer, Stanley Furniture Company, Inc.
1641 Fairystone Park Highway
Stanleytown, VA 24168

Re:	Stanley Furniture Company, Inc.
      Form 10-K for the fiscal year ended December 31, 2004
      File No. 0-14938

Dear Mr. Payne:

We have reviewed these filings and have the following comments.
If
you disagree with a comment, 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 supplemental
information
so we may better understand your disclosure.  After reviewing this
information, we may or may not 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.

10-K for the Period Ended December 31, 2004

General

1. Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like.  These revisions should be
included in your future filings.

Liquidity and Capital Resources-Table of Contractual Obligations

2. Please revise your table of contractual cash obligations to
also
include the following:
(a)	Estimated interest payments on your debt, and
(b)	Estimated future benefit payments related to your pension and
postretirement benefits.
Because the table is aimed at increasing transparency of cash
flow,
we believe these payments should be included in the table.  Please
also disclose any assumptions you made to derive these amounts.

Item 7A-Quantitative and Qualitative Disclosures about Market Risk

3. We note that 4% of your 2004 net sales were to international
customers.  Please include a discussion regarding your foreign
currency exchange rate risk.  Indicate if your foreign sales and
purchases are denominated in foreign currencies and if so, whether
you are hedging those transactions.  Refer to Item 305 of
Regulation
S-K.

*     *     *

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
supplemental response letter that keys your responses to our
comments
and provides any requested supplemental information.  Detailed
letters greatly facilitate our review.  Please file your
supplemental
response on EDGAR as a correspondence file.  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 filings reviewed by the staff to be
certain
that they have provided all information investors require.  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 filings;
* 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 Mindy Hooker, Staff Accountant, at (202) 824-5459 or to
the
undersigned at (202) 824-5373.

Sincerely,

John Cash
Accounting Branch Chief
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Stanley Furniture Company, Inc.
Form 10-K
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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