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CORRESP
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      Response Letter to the SEC

              AMERICA’S
                CAR-MART, INC.

               802
                S.E. Plaza Ave. Suite 200

              PO
                Box 2580

              Bentonville,
                Ar 72712

              Phone:
                479-464-9944

              Fax:
                479-464-4234

               www.car-mart.com

    May
      10,
      2007

    VIA
      EDGAR

    Scott
      Ruggiero

    Staff
      Accountant

    Division
      of Corporation Finance

    Securities
      and Exchange Commission

    100
      F
      Street, N.E.

    Washington,
      D.C. 20549

              RE:

                America’s
                  Car-Mart, Inc.

                  Form
                    10-K for the Fiscal Year Ended April 30, 2006 Filed 7-14-06

                  For
                    10-Q for the Quarter Ended 1-31-07

                  File
                    No. 0-14939

    Dear
      Mr.
      Ruggiero:

    On
      behalf
      of America’s Car-Mart, Inc. (the “Company”), this responds to your letter dated
      April 26, 2007 regarding the Company’s Annual Report on Form 10-K for the year
      ended April 30, 2006 and for the Quarterly Report on Form 10-Q for the period
      ended January 31, 2007. For ease of reference, your comments are set forth
      below, followed by our response.

    Form
      10-K for the Fiscal Year ended April 30,2006

    Management’s
      Discussion and Analysis of Financial Condition and Results of Operations, page
      20

    Contractual
      Obligations, page 27

    Comment

              1.

              Please
                revise your tabular disclosure of contractual obligations in future
                filings to include estimated interest payments on your debt. Since
                the
                table is aimed at increasing transparency of cash flow, we believe
                these
                payments should be included in the table. A footnote to the table
                should
                provide appropriate disclosures regarding how you estimated the interest
                payments. If you choose not to include these payments, a footnote
                to the
                table should clearly identify the excluded item and provide any additional
                information that is material to an understanding of your cash
                requirements. See item 303(a)(5) of Regulation S-K and footnote 46
                to SEC
                Release No. 33-8350.

    Response

    We
      acknowledge your comment. The Company will include estimated interest payment
      on
      our debt in the Contractual Obligations table along with appropriate disclosures
      regarding how we estimated the interest payments in accordance with the guidance
      in Item 303(a)(5) of Regulation S-K and SEC Release No.
      33-8350.

      Scott
        Ruggiero

      May
        10,
        2007

      Page
        2 of
        4

    Consolidated
      Balance Sheets, page 33

    Comment

              2.

              We
                noted from your disclosure at page 39 that you include goodwill in
                the
                “Prepaid expenses and other assets” line item of your balance sheet. In
                future filings, please present goodwill as a separate line item.
                Refer to
                paragraph 43 of SFAS 142.

    Response

    In
      future
      filings, the Company will present goodwill as a separate line item from “prepaid
      expenses and other assets” in accordance with the guidance provided in SFAS 142,
      paragraph 43.

    Comment

              3.

              We
                note that the equity section of your April 30, 2006 balance sheet
                does not
                sum correctly. In addition, we note that your additional paid-in
                capital
                balances as of April 30, 2006 and 2005 do not agree to the amounts
                presented in your consolidated statement of stockholders’ equity for the
                corresponding year end dates. Please correct these amounts as appropriate
                in future filings.

    Response

    The
      error
      occurred during a final adjustment proposed by draft review comments to separate
      treasury stock from common stock. The adjusted amounts were not picked up
      correctly in the final printing draft used for the Edgar submittal. We will
      correct these errors in our future filings.

    Consolidated
      Statements of Cash Flows, page 35

    Comment

              4.

              We
                note that you present the proceeds from and repayments of your revolving
                credit facility on a net basis. It does not appear from your disclosure
                at
                page 44 that the turnover of your revolving credit facility is quick.
                Therefore, please revise your statements of cash flows to present
                these
                amounts on a gross basis. Please refer to paragraph 13 of SFAS 95.
                Also,
                please revise your statements of cash flows to include cash overdrafts
                in
                the financing activities section.

    Response

    In
      future
      filings, the Company will present the proceeds from and repayments of our
      revolving credit facility on a gross basis in accordance with SFAS 95, paragraph
      13 and cash overdrafts, if any, in the financing activities
      section.

      Scott
        Ruggiero

      May
        10,
        2007

      Page
        3 of
        4

    Notes
      to Consolidated Financial Statements, page 37

    B
      - Summary of Significant Accounting Policies, page 37

    Inventory,
      page 39

    Comment

              5.

              Please
                tell us the basis for your statement that the fair value of repossessed
                vehicles approximates wholesale value considering that your retail
                outlets
                allow you to offer repossessed vehicles at retail
                prices.

    Response

    The
      fair
      value of repossessed vehicles is determined by the amount our wholesalers would
      purchase the vehicle from us or similarly by the price the wholesaler would
      sell
      that same vehicle back to us for. Whether we repossessed that vehicle or
      purchased a comparable vehicle from our wholesaler, the vehicle value (or cost)
      would be the same and represents the fair value of that vehicle.

    Our
      retail price is based upon a formula which marks up the cost (or fair value)
      of
      the vehicle to a retail price. Therefore, repossessed vehicles on our inventory
      listing approximate the price we would get from our wholesaler which is the
      same
      price our wholesaler would sell that same vehicle back to us for.

    Exhibit
      31.1 and 31.2

    Comment

              6.

              We
                note the identification of the certifying individuals at the beginning
                of
                the certifications required by Exchange Act Rule 13a-14(a) also includes
                the titles of the certifying individuals. In future filings, the
                identification of the certifying individuals at the beginning of
                the
                certification should be revised so as not to include the individual’s
                titles.

    Response

    In
      future
      filings, we will not include the titles of the certifying individuals at the
      beginning of the certifications required by Exchange Act Rule
      13a-14(a).

    Form
      10-Q for the Fiscal Quarter Ended January 31, 2007

    Consolidated
      Statements of Cash Flows, page 4

    Comment

              7.

              We
                note from your presentation and from your disclosure at page 7 that
                you
                reported $127,000 of excess tax benefits related to your equity
                instruments in the financing activities section of your statements
                of cash
                flows. Note that you should also report this amount as a reconciling
                item
                in the operating activities section. Please revise your statements
                of cash
                flows accordingly. Refer to paragraph 23(c) of SFAS 95 and paragraph
                68 of
                SFAS 123(R).

      Scott
        Ruggiero

      May
        10,
        2007

      Page
        4 of
        4

    Response

    We
      reported the $127,000 in excess tax benefits in the operating activities
      section; however, we incorrectly netted the amount with the change in income
      tax
      payable. In future filings, we will revise our statements of cash flows to
      separately state excess tax benefits as a cash outflow from operating activities
      and a cash inflow from financing activities in accordance with paragraph 68
      of
      SFAS 123(R).

    The
      Company hereby acknowledges that:

              ·

              the
                Company is responsible for the adequacy and accuracy of the disclosure
                in
                the filings;

              ·

              comments
                by the staff of the Securities and Exchange Commission or changes
                to
                disclosure in response to staff comments do not foreclose the Commission
                from taking any action with respect to the filings;
                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.

    If
      you
      should have any questions or further comments with respect to the Company’s
      filings, please direct them to me at (479) 418-8021.

              Very
                truly yours,

              /s/
                Jeffrey A. Williams

              Jeffrey
                A. Williams

              Vice
                President Finance and

              Chief
                Financial Officer