SecProbe.io

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<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                 March 29, 2005

John Cash
Accounting Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

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

Dear Mr. Cash:

     This letter  responds to the  comments of the staff of the  Securities  and
Exchange  Commission  (the  "Commission")  communicated  by letter (the "Comment
Letter") dated March 16, 2004 with respect to the Form 10-K of Stanley Furniture
Company,  Inc. for the fiscal year ending December 31, 2004 (the "Filing").  For
your convenience, the headings and paragraph numbers in our letter correspond to
the headings and paragraph numbers in the Comment 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.

     We have provided the requested  revisions and will include these  revisions
     in our 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.

     The  revised  table   including  the  requested   information  and  related
     assumptions is set forth below:

     The following table sets forth our contractual  cash  obligations and other
     commercial commitments at December 31, 2004:
<TABLE>
<CAPTION>

                                                      Payment due or commitment expiration
                                                ----------------------------------------------
                                                       Less than                         Over
Contractual cash obligations:                   Total    1 year   1-3 years 3-5 years  5 years
<S>                                           <C>       <C>       <C>       <C>       <C>
Long-term debt .............................   $15,685   $ 4,257   $ 5,714   $ 2,857   $ 2,857
Postretirement benefits other than pensions(1)   4,857       290       550       535     3,482
Fixed interest payments on long-term debt ..     3,120     1,016     1,311       595       198
Operating leases ...........................     2,821       701     1,182       938
                                               -------   -------   -------   -------   -------

Total contractual cash obligations .........   $26,483   $ 6,264   $ 8,757   $ 4,925   $ 6,537
                                               =======   =======   =======   =======   =======

Other commercial commitments:
Letters of credit ..........................   $ 4,234   $ 4,234
                                               =======   =======

<FN>
(1)  The '83 Group  Annuity  Mortality  tables  were used in  estimating  future
     benefit  payments,  and the health  care cost  trend  rate for  determining
     payments is 10% for 2005 and gradually declines to 5.5% in 2010 where it is
     assumed to remain constant for the remaining years.
</FN>

     Our pension plan is frozen and under current  valuations  holds  sufficient
assets to cover  future  benefit  obligations.  Therefore,  we do not  currently
anticipate any cash funding needs to meet minimum required funding thresholds.
</TABLE>

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.

     None of our sales or purchases are  denominated in foreign  currencies.  We
     propose to include the following sentence in our future filings:

     "None of our foreign sales or purchases are denominated in foreign currency
     and we do not have any foreign currency hedging transactions."

     As  requested  in the  Comment  Letter,  we  acknowledge  that (i)  Stanley
Furniture Company is responsible for the adequacy and accuracy of the disclosure
in its  filings;  (ii) 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 (iii) we 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.

                                                     Sincerely,

                                                     /s/ Douglas I. Payne
                                                     --------------------
                                                     Douglas I. Payne
                                                     Executive Vice President
                                                     Finance and Administration

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