SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
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                       March 22, 2005

Ms. Linda Cvrkel
Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 03-05
Washington, D.C.  20549

     RE:  Patriot Transportation Holding, Inc.
          Form 10-K for the year ended September 30, 2004
          Form 10-Q for the quarter ended December 31, 2004
          Commission File #: 000-17554

Dear Ms. Cvrkel:

     Thank you for your correspondence dated March 18, 2005.
We  appreciate  your  assistance with  compliance  with  the
applicable disclosure requirements.

      Our responses to your comments are set forth below and
have been keyed to your comments.

FORM 10-K FOR THE YEAR ENDED SEPTEMBER 30, 2004

Schedule II.  Valuation and Qualifying Accounts
------------------------------------------------

  1. We note from your response to comment 3 that the reason
     the accrued balances at the beginning of 2003 and 2004 were
     significantly less than the expenses in the following years
     was due to insurance premiums.  Based upon your response, it
     appears that insurance premiums expenses are not  being
     included in your accruals.  Please explain why.

     COMPANY RESPONSE: Insurance premiums are not  included
     in  the  accrued balances at the beginning of  2003  or
     2004.  However, insurance premiums are included in  the
     columns  "Additions Charged to Costs and Expenses"  and
     "Deductions".   The  Company's risk insurance  policies
     run  from October 1 through September 30.  All premiums
     are  paid and expensed within each fiscal

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     year so there is   no  beginning  or  ending  accrual  for
     insurance premiums.   The following schedule should help
     clarify my response:

<TABLE>
<CAPTION>

                       Balance at   Additions   Additions     Deductions  Balance at
                       Beginning    Charged to  Charged to    And         End
                       of Year      Expenses    Other Accts   Payments    of Year

YEAR ENDING 9/30/04:

<s>                    <c>          <c>         <c>           <c>         <c>
Claims                 6,779,345    3,562,400                 3,688,088   6,653,657
Premiums                       0    4,406,016                 4,406,016           0
                       ---------    ---------   ---------     ---------   ---------
Accrued Risk Insurance 6,779,345    7,968,416                 8,094,104   6,653,657

YEAR ENDED 9/30/2003:

Claims                 6,326,406    4,151,065                 3,698,126   6,779,345
Premiums                       0    3,838,509                 3,838,509           0
                       ---------    ---------   ---------     ---------   ---------
Accrued Risk Insurance 6,326,406    7,989,574                 7,536,635   6,779,345

</table>

The Company hereby acknowledges that:

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

     * staff comments and changes to disclosure in response to
       staff comments in the filings reviewed by the staff 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.

     If  you  have  any comments or questions regarding  our
responses, please contact me at the above-listed address  or
by telephone at (904) 396-5733 Ext. 3100.

                                   Sincerely,

                                   /s/ Ray M. Van Landingham

                                   Ray M. Van Landingham
                                   Vice President and
                                   Chief Financial Officer

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