SecProbe.io

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Mail Stop 4561

      May 25, 2005

Michael A. Hartley
Chief Financial Officer
LMR Land Company, Ltd.
3310 West End Avenue, Suite 490
Nashville, Tennessee  37203

      Re:	LMR Land Company, Ltd.
      Form 10-K for the fiscal year ended December 31, 2004
      Filed March 29, 2005
      	File No. 0-16727

Dear Mr. Hartley:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that 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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the fiscal year ended December 31, 2004

Controls and Procedures
1. We note your disclosure that the President and Vice President
of
the General Partner concluded on the effectiveness of disclosure
controls and procedures based upon their evaluation within 90 days
of
the filing date of Form 10-K.  Please advise us why these
conclusions
on the effectiveness of disclosure controls and procedures were
not
as of the end of the fiscal year as required by Item 307 of
Regulation S-K.  Amend your filing for this disclosure, as
appropriate.  Additionally, please amend paragraph 4(b) of the
certifications located in Exhibits 31.1 and 31.2. Refer to Item
601
of Regulation S-K.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision.  Since the company and
its management are in possession of all facts relating 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
disclosure in the filing;

* 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

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Howard Efron, Staff Accountant, at (202) 551-
3439 or me at (202) 551-3403 if you have questions regarding
comments
on the financial statements and related matters.

								Sincerely,

      Steven Jacobs
      Branch Chief

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Michael A. Hartley
LMR Land Company, Ltd.
May 25, 2005
Page 3

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