SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 4561

      May 27, 2005

Bruce A. Provo
Chief Executive Officer
Divall Insured Income Properties 2 Limited Partnership
1100 Main Street, Suite 1830
Kansas City, Missouri  64105

      Re:	Divall Insured Income Properties 2 Limited Partnership
      Form 10-K for the fiscal year ended December 31, 2004
      Filed March 4, 2005
      	File No. 0-17686

Dear Mr. Provo:

      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

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Other Investment in Properties Information, page 22
1. We note your disclosure that the owners of the Panda Buffet
have
an option to purchase the property that they are currently leasing
from you at a price that is in excess of the original cost of the
property less accumulated depreciation.  Please advise us and
disclose in future filings the terms of the purchase option in
accordance with paragraph 16 of SFAS 13.  Additionally, please
clarify for us your considerations in determining that the Panda
Buffet lease should be classified as an operating lease with
respect
to whether or not the lease contained a bargain purchase option.
Reference is made to paragraph 5(d) of SFAS 13.

Financial Statements

Leases, page 47
2. The staff believes that the financial statements of properties
leased to single tenants on a long term basis under triple net
leases
whose carrying values exceed 20% of the registrant`s total assets
are
relevant to the investor.  Since the properties leased to WenCoast
restaurants appears to exceed 20% of the registrant`s total assets
and are leased to a single tenant under a triple net lease, please
amend to provide audited financial statements of the properties or
audited financial statements of the tenant, whichever is more
relevant.  Refer to SAB 71 by analogy.

Exhibit 31.1
3. Please amend certification paragraphs 4 and 5 of Exhibit 31.1
for
consistency with 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 file your cover letter on EDGAR.
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

??

??

??

??

Bruce A. Provo
Divall Insured Income Properties 2 Limited Partnership
May 27, 2005
Page 3

</TEXT>
</DOCUMENT>