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Mail Stop 3561           June 18, 2009   William H. Henderson Chief Executive Officer America’s Car-Mart, Inc. 802 Southeast Plaza Avenue, Suite 200 Bentonville, Arkansas  72712
 Re: America’s Car-Mart, Inc.
  Form 10-K for Fiscal Year Ended April 30, 2008   Filed July 3, 2008   Definitive Proxy Statement on Schedule 14A   Filed August 28, 2008
Form 10-Qs for the Quarterly Peri ods Ended July 31, 2008, October 31, 2008
and January 31, 2009
  Filed September 9, 2008, December 5, 2008 and March 9, 2009
Form 8-K
  Filed June 26, 2008
  File No. 000-14939

Dear Mr. Henderson:   We have reviewed your response letter  dated May 13, 2008 and filed May 21, 2009 and
have the following comments.  You should comply with these comments in all future filings, if
applicable.  Please confirm in writing that you w ill do so and also explain to us in sufficient
detail how you intend to comply by providing us with your proposed revisions.  If you disagree,
we will consider your explanation as to why our  comment is inapplicable or a revision is
unnecessary.  Please be as detaile d as necessary in your explan ation.  After reviewing this
information, we may raise additional comments.  Form 10-K for Fiscal Year Ended April 30, 2008

 Note B – Summary of Significan t Accounting Policies, page 36

 1. We have reviewed your response to prior comment 4 in our letter dated April 16, 2009
noting that you have aggregated  individual lots into one ope rating segment.  Considering
operating segments are aggregated into a re portable segment if the operating segments
meet the aggregation criteria of paragra ph 17 of SFAS 131, your re sponse suggests that

William H. Henderson
America’s Car-Mart, Inc. June 18, 2009 Page 2
each lot represents an operating segment.  Please clarify how you determined your operating segments by identifying your chief op erating decision maker and telling us if
the CODM regularly reviews the results of your  individual lots.  As noted in paragraph
10 of SFAS 131, an operating segment is a comp onent of an enterprise whose operating
results are regularly reviewed by the CODM.  If your CODM does not regularly review
the results of individual lots, tell us the le vel of your business regularly reviewed by the
CODM.
 Finance Receivables, Repossessions and Charge-o ffs and Allowance for Credit Losses, page 37

 2. We have reviewed your response to prior comment 5 in our letter dated April 16, 2009
and have the following comments:
• Please confirm that the loans you provide cust omers are simple interest loans and not
pre-computed loans whereby borrowers are ob ligated to pay back principal plus the
full amount of interest that will acc rue over the entire te rm of the loan.

• You indicate that impaired loans do not remain on your books for an extended period
of time and your average account loss is taken within 53 days of it becoming
delinquent.  Please clarify if an account gene rally becomes delinquent at 30 days or at
some later point in time.  Please also cl arify why loans are no t placed on nonaccrual
status prior to write-off or repossession of the vehicle.
 Note J – Stock Options and Warrants, page 49

 3. We have reviewed your response to prior co mment 9 in our letter dated April 16, 2009.
In complying with paragraph A240(b)(1)( c) of SFAS 123(R), please confirm that you
will disclose in future filings the number and weighted-average exercise price of options
exercisable at year-end.

Note C – Finance Receivables, Net, page 45

 4. We have reviewed your response to prior co mment 10 in our letter dated April 16, 2009.
Please disclose in future filings the informati on discussed in Instructi on 2 to Item IV.A of
Industry Guide 3.
 Note H – Capital Stock, page 48

 5. We have reviewed your response to prior co mment 11 in our letter dated April 16, 2009.
Please note that paragraph 11 of SFAS 150 requi res liability classification for instruments
where the issuer, under no condition, may a void such obligations.  Contingently
redeemable securities, such as puttable st ock redeemable at the holder’s option, are
outside the scope of SFAS 150 a nd are classified within perm anent or mezzanine equity
and reclassified as a liability when the contin gent event has occurred or becomes certain

William H. Henderson
America’s Car-Mart, Inc. June 18, 2009 Page 3
to occur, thus making the securities uncondi tionally redeemable.  Based on Rule 5-02.28
of Regulation S-X, it appears that your redeemable preferre d stock should be classified
within mezzanine equity and the dividends shoul d be reflected as a reduction of retained
earnings.  If you agree, please re vise your financial statements and tell us the impact that
these errors had on your historic al financial statements.

Note L – Fair Value of Financial Instruments, page 51

 6. We have reviewed your response to prior co mment 12 in our letter dated April 16, 2009.
As we believe the information provided in you r response would be beneficial to a reader
of your financial statements, please disclose in future filings the reasons why the fair
value of your net finance receivable is signi ficantly less than its carrying value.

Form 10-Q for the Quarterly Period Ended January 31, 2009

 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
13
 7. We have reviewed your response to prior co mment 21 in our letter dated April 16, 2009.
Please tell us and disclose in further detail  in future filings the specific improvements
made to your underwriting and collection procedures.

* * *

You may contact Andrew Blume at (202)  551-3254 or in his absence, Jennifer
Thompson, at (202) 551-3737 if you have ques tions regarding comments on the financial
statements and related matters.  Please contac t Chris Chase, Attorney-Advisor, at (202) 551-
3485, Ellie Bavaria, Special Counsel, at (202) 55 1-3238 or me at (202) 551-3725 with any other
questions.
        S i n c e r e l y ,            H. Christopher Owings        A s s i s t a n t  D i r e c t o r