SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
CF/AD5
100 F STREET, NE
WASHINGTON, D.C. 20549-3561

       DIVISION OF
CORPORATION FINANCE

        September 29, 2008

Via Mail and Fax

Yaron Shalem
Chief Financial Officer
TAT Technologies Ltd.
P.O. Box 80
Gedera 70750, Israel

 RE:  TAT Technologies Ltd.
Form 20-F for the Year Ended December 31, 2007
Form 6-K filed August 15, 2008
   File Number: 000-16050

Dear Mr. Shalem:

 We have reviewed the above referenced filings and have the following comments.
Unless otherwise indicated, we believe you should revise future filings in response to our
comments.  If you disagree, we will consider your explanation as to why a revision is not
necessary.  Please be as detail ed as necessary in your explanation.  We also ask you to
provide us with information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

 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 filings.
We look forward to working with you in thes e respects and welcome any questions.  Feel
free to call us at the telephone numbers  listed at the end of this letter.

 Please file your response to our comment s via EDGAR, under the label “corresp,”
and any associated amended fili ngs within 10 business days from  the date of this letter.

TAT Technologies Ltd.
September 29, 2008
Page 2 of 4
Form 20-F for the Year Ended December 31, 2007

Item 5. Operating and Financial Review and Prospects, page 25
A. Operating Results, page 25
Overview, page 26

1. We note from the segment note (note 13) of th e notes to the financial statements that
“gross profit” and “operating income” for each segment as a percentage of its revenues differ between the segments.  In th is regard, please address on an overview
basis the significant factors affecting these ratios of each segment and the
comparability of such ratios between se gments.  Additionally, address any known
trends, demands and uncertainties affecting or that will affect the results of operations, liquidity or cash requirements of  each segment, particularly in view of
circumstances that may be addressed in disclosures associated with the following two comments.  We believe the disclosures i ndicated above and in the following two
comments will help investors better unders tand your operations and the contributions
by each segment to your consolidated results.

Year Ended December 31, 2007 Compared w ith Year Ended December 31, 2006, page
32

2. Please disclose the cost of revenues of each segment as a percentage of its revenues
for each period reported.  Accompany this with  disclosure of the reasons for variances
therein between comparative periods for each segment.  For example, we note that cost of revenues as a percent of rela ted revenues was 71.3%, 73.5% and 77.6% for
MRO services, 70.8%, 68.0% and 64.7% for OEM products, and 81.5%, 84.5% and
69.3% for parts services for 2007, 2006 and 2005, respectively.

3. For consistency with the information presen ted in your segment note, please include a
comparative analysis of operating income for each segment for each period reported.

B. Liquidity and Capital Resources, page 40

4. In the fourth paragraph on page 41 you di sclose that capital e xpenditures for 2007 of
$6.3 million were funded by cash flow from operations.  However, cash flow from operating activities for 2007 was only $804 thousand.  Please clarify.

Cash Flows, page 41

5. Please discuss in terms of cash the signi ficant factors and associated underlying
reasons that contributed to the materi al changes in cash provided by operating
activities between comparative periods.  Note  that references to line items (or changes
therein) in the statements of cash flows, as  in your present disclosure, do not provide
a sufficient basis for an investor to anal yze the impact on cash.  Refer to Section
IV.B.1 of “Interpretation: Commissi on Guidance Regarding Management's

TAT Technologies Ltd.
September 29, 2008
Page 3 of 4
Discussion and Analysis of Financial Cond ition and Results of Operations” available
on our website at http://www.sec.gov/rules/interp/33-8350.htm  for guidance.

Notes to Consolidated Financial Statements, page F-10
Note 1.c – General, page F-10

6. Please explain to us and disclose how the $26.4 million gain related to Limco-Piedmont was computed.

Note 2 – Significant Accounting Policies, page F-14
c. Principles of c onsolidation, page F-14

7. Please disclose your accounting for investme nts in less than wholly-owned entities,
for example, Limco-Piedmont.

l. Revenue recognition, page F-19

8. Your disclosures indicate that you have multiyear, fixed price contracts for your OEM customers and customers for MRO services.  Please disclose the basis upon which revenue is allocated under such resp ective contracts and how  associated costs
are recognized.  Include in your disclosure how losses associated with such respective
contracts are determined and recognized.  Provide us with a copy of your intended revised disclosure.

Note 3 – Inventories, page F-27

9. Please explain to us the reason for the in crease in the spare parts inventory to $6.9
million at December 31, 2007 from $795 thousand at December 31, 2006.

Note 13 – Segment and Major Customer Information, page F-42

10. Please explain to us and disclose the r eason for the comparatively higher amount of
general and administrative expenses of the OEM segment relative to the other
segments as a percentage of segment revenue s, and the basis of attribution of such
expenses to the respective segments.

Form 6-K filed August 15, 2008

11. We note your disclosure that a decrease in  the net earnings of Limco-Piedmont was
due in part to an inventory adjustment.  Please quantify for us the amount of, and explain to us the circumstances a ssociated with, this adjustment.

TAT Technologies Ltd.
September 29, 2008
Page 4 of 4
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in filings to be certain that th e filings include all information required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 disclosures in the 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 filings; and
‚ the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

You may contact Doug Jones at 202-551-3309 with any questions.  You may also
contact me at 202-551-3380.

 Sincerely,

 Lyn Shenk
Branch Chief