SecProbe.io

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                      [LETTERHEAD OF TAT TECHNOLOGIES LTD.]

Mr. Lyn Shenk
Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

October 29, 2008

                      RE:  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. Shenk:

We are submitting this letter in response to the written comments of the Staff
of the Securities and Exchange Commission (the "Staff") in a letter addressed to
Mr. Yaron Shalem, Chief Financial Officer of TAT Technologies Ltd. (the
"Company"), dated September 29, 2008, with respect to the Company's Annual
Report on Form 20-F for the fiscal year ended December 31, 2007 (the "Form
20-F") and Form 6-K filed on August 15, 2008.

The paragraphs below are numbered to correspond to the Staff's comments as set
forth in your letter dated September 29, 2008. In each instance, we have
repeated your comment in italics and boldface and set forth our response in
plain type below the relevant comment.

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 THE 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 THIS REGARD,
    PLEASE ADDRESS ON AN OVERVIEW BASIS THE SIGNIFICANT FACTORS AFFECTING THESE
    RATIOS OF EACH SEGMENT AND THE COMPARABILITY OF SUCH RATIOS BETWEEN
    SEGMENTS. 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 INDICATED ABOVE AND IN THE FOLLOWING TWO COMMENTS
    WILL HELP INVESTORS BETTER UNDERSTAND YOUR OPERATIONS AND THE CONTRIBUTIONS
    BY EACH SEGMENT TO YOUR CONSOLIDATED RESULTS.

     We will in the future revise our overview in response to this comment to
     provide the following additional disclosure:

<PAGE>

     We provide a variety of services and products to the aerospace industry and
     report our revenues for these services and products under three segments:
     (i) OEM products (ii) MRO services and (iii) parts, each with the following
     characteristics:

     -    Our OEM activities  primarily  relate to the manufacture and sale of a
          broad  range of heat  transfer  components  (such as heat  exchangers,
          pre-coolers  and oil/fuel  hydraulic  coolers) used in mechanical  and
          electronic   systems  on-board   commercial,   military  and  business
          aircraft. We also manufacture and sell other environmental control and
          cooling  systems  and a variety  of other  electronic  and  mechanical
          aircraft  accessories and systems such as pumps, valves, power systems
          and turbines.

     -    Our MRO  services  include the  remanufacture,  overhaul and repair of
          heat  transfer   equipment  and  other  aircraft   components,   APUs,
          propellers and landing gear. Our  Limco-Piedmont  subsidiary  operates
          four FAA certified repair stations,  which provide aircraft  component
          MRO services for airlines,  air cargo  carriers,  maintenance  service
          centers and the military.

     -    Our parts  segment  focuses  on the sale of APU parts  propellers  and
          landing gear.  We offer parts  services for  commercial,  regional and
          charter airlines and business aircraft owners.

     We are reliant on the commercial and military aircraft industries. Any
     downturn in these industries could decrease demand for our services and
     products and negatively impact our financial condition. The commercial
     airline industry is cyclical and has historically been subject to
     fluctuations due to general economic and political conditions, such as fuel
     and labor costs, price competition, downturns in the global economy and
     national and international events.

     Our cost of revenues for OEM products and MRO services consists of
     component and material costs, direct labor costs, shipping expenses,
     overhead related to manufacturing and depreciation of manufacturing
     equipment. Our cost of revenues for parts services consists primarily of
     the cost of the parts and shipping expenses. Our gross margin is affected
     by the proportion of our revenues generated from MRO services, OEM products
     and parts services.

     Our revenues from MRO services and OEM products generally have higher gross
     margins than from parts services, where the historical gross margins are
     generally lower. The manufacture of OEM products and the provision of MRO
     services require higher level of expertise, associated labor and initial
     investments than does the provision of parts services. These factors and
     the long-term relationships we have maintained with our customers generate
     higher margins.

     The principal factors that affect the operating income of our three
     segments in addition to their gross profit, is the amount we expend for
     selling and marketing expenses and general and administrative expenses. We
     believe that our selling and

                                        2

<PAGE>

     marketing expenses will increase in the future in accordance with our plans
     to grow the business of these segments, along with our intention to
     decrease general and administrative expenses.

     Our selling and marketing expenses for our MRO services have continued to
     grow during the last three years due to our increased sales in this segment
     and our efforts to grow this business segment. We expect that our MRO
     selling and marketing expenses will continue to increase in the future with
     the expected growth of this segment. Our selling and marketing expenses for
     our OEM products have been relatively stable during the last three years,
     consistent with the sales growth of this segment. We expect that our OEM
     selling and marketing expenses will increase in the future in accordance
     with our expected efforts to grow this business segment. Our selling and
     marketing expenses for our parts services have increased during the last
     three years as this segment has grown, but such expenses are significantly
     lower than for our other two segments. We believe that such expenses will
     increase in the future in accordance with our intent to grow this business
     segment.

     Our general and administrative expenses have grown in recent years as a
     result of the initial public offering of our Limco-Piedmont subsidiary and
     our expenditures with respect to Sarbanes-Oxley compliance. The general and
     administrative expenses of our MRO services segment have also increased due
     to the growth of this segment and the necessary growth in general and
     administrative expenditures. Our general and administrative expenses for
     our OEM products segment have increased during the last three years,
     increasing significantly in 2007. In addition to the factors explained
     above, the increase in general and administrative expenses of our OEM
     segment expenses is also attributable to increased salary expenses
     including bonuses and expenditures with respect to Sarbanes-Oxley
     compliance. Our general and administrative expenses for our parts services
     segment were relatively stable during the last three years. The limited
     increase in such expenses is due to the growth of this segment. We expect
     that our general and administrative expenses as a percentage of revenues
     will decline in the future with our anticipated growth in revenues.

YEAR ENDED DECEMBER 31, 2007 COMPARED WITH 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 RELATED 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.

     We will in the future revise our discussion in response to this comment to
     provide the following additional disclosure.

                                        3

<PAGE>

Cost of revenues. Cost of revenues increased to $65.2 million for the year ended
December 31, 2007 from $57.6 million for the year ended December 31, 2006, an
increase of 13.0%. The increase in cost of revenues was primarily attributable
to the increase in our OEM and MRO services revenues and the significant
increase in parts services revenues, resulting in increased costs. Cost of
revenues as a percentage of revenues after eliminating intercompany transactions
decreased to 73.5% in the year ended December 31, 2007 from 74.3% for the year
ended December 31, 2006, primarily as a result of our continued efforts to
improve our operating efficiencies. We expect that our cost of revenues will
increase in 2008 consistent with the expected increase in our revenues. All of
the following cost of revenues data reflect the elimination of inter-company
transactions.

         Cost of revenues for MRO services. Cost of revenues for MRO services
increased to $35.2 million for the year ended December 31, 2007 from $32.2
million for the year ended December 31, 2006, an increase of 9.3%, primarily as
a result of our increased revenues, resulting in increased costs. Cost of
revenues as a percentage of revenues decreased to 71.3% in the year ended
December 31, 2007 from 73.5% for the year ended December 31, 2006, primarily as
a result of our efforts to improve the profitability of our MRO services
segment. We expect that our cost of revenues for MRO services will increase in
2008 consistent with the expected increase in our revenues and increased labor
costs.

         Cost of revenues for OEM products. Cost of revenues for OEM products
increased to $13.4 million for the year ended December 31, 2007 from $12.6
million for the year ended December 31, 2006, an increase of 4.7%, primarily as
a result of our increased revenues. Cost of revenues as a percentage of revenues
increased to 70.8% in the year ended December 31, 2007 from 68.0% for the year
ended December 31, 2006, primarily as a result from a change in the product mix
and increased production costs in 2007. We expect that our cost of revenues for
OEM products will increase in 2008 consistent with the expected increase in our
revenues and increased labor costs.

         Cost of revenues for parts services. Cost of revenues for parts
services increased to $16.6 million for the year ended December 31, 2007 from
$12.8 million for the year ended December 31, 2006, an increase of 29.7%,
primarily as a result of our increased parts revenues. Cost of revenues as a
percentage of revenues decreased to 81.5% in the year ended December 31, 2007
from 84.5% for the year ended December 31, 2006, primarily as a result of our
efforts to improve the profitability of our parts segment during 2007. We expect
that our cost of revenues for parts services will vary from year to year and
period to period due to the high degree of volatility in this segment.

                                        4

<PAGE>

    3. FOR CONSISTENCY WITH THE INFORMATION PRESENTED IN YOUR SEGMENT NOTE,
    PLEASE INCLUDE A COMPARATIVE ANALYSIS OF OPERATING INCOME FOR EACH SEGMENT
    FOR EACH PERIOD REPORTED.

We will in the future provide the following additional disclosure in response to
this comment:

The presentation of operating income data is after elimination of intercompany
transactions of $1.6 million in the year ended December 31, 2007 and $1.3
million in the year ended December 31, 2006 and net of corporate general and
administrative expenses of $5.0 million in the year ended December 31, 2007 and
$2.8 million in the year ended December 31, 2006.

Operating income. Operating income decreased to $8.8 million for the year ended
December 31, 2007 from $9.7 million for the year ended December 31, 2006, a
decrease of 9.6%. The decrease in operating income was primarily attributable to
an increase in general and administrative expenses and to a lesser extent to an
increase in selling and marketing expenses in 2007. The increased expenses were
primarily attributable to the initial public offering of our Limco-Piedmont
subsidiary, expenditures with respect to Sarbanes-Oxley compliance and increased
salary expenses.

          Operating income for MRO services. The operating income of our MRO
services segment increased to $10.1 million for the year ended December 31, 2007
from $8.7 million for the year ended December 31, 2006, an increase of 15.5%,
primarily as a result of the increase in revenues of this segment, offset in
part by the increase in general and administrative and selling and marketing
expenses in 2007. Operating income as a percentage of revenues increased
slightly to 20.5% in the year ended December 31, 2007 from 20.0% for the year
ended December 31, 2006.

          Operating income for OEM products. The operating income of our OEM
products segment decreased to $2.5 million for the year ended December 31, 2007
from $3.7 million for the year ended December 31, 2006, a decrease of 32.2%,
primarily as a result of an increase in general and administrative expenses
attributable to this segment in 2007. The increase in expenses resulted from
increased salary expenses including bonuses, and expenditures with respect to
Sarbanes-Oxley compliance. As a result of these increased expenses, operating
income as a percentage of revenues decreased to 10.6% in the year ended December
31, 2007 from 16.5% for the year ended December 31, 2006.

         Operating income for parts services. The operating income of our parts
services segment increased to $2.8 million for the year ended December 31, 2007
from $1.3 million for the year ended December 31, 2006, an increase of 108%,
primarily as a result of the increased revenues and profitability of this
segment. Operating income as a percentage of revenues increased to 13.7% in the
year ended December 31, 2007 from

                                       5

<PAGE>

8.6% for the year ended December 31, 2006, primarily as a result of an increase
in the absolute gross profit arising from the increased revenues.

B. LIQUIDITY AND CAPITAL RESOURCES, PAGE 40
-------------------------------------------

    4. IN THE FOURTH PARAGRAPH ON PAGE 41 YOU DISCLOSE THAT CAPITAL EXPENDITURES
    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.

We will in the future revise the disclosure in the fourth paragraph in response
to this comment as follows.

Capital expenditures for the years ended December 31, 2007, 2006 and 2005 were
approximately $6.3 million, $1.7 million and $1.1 million, respectively. These
capital expenditures were principally for the purchase of equipment for our OEM
and MRO