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  GTSI
  Corp.

  3901
  Stonecroft Boulevard

  Chantilly,
  VA 20151

  703-502-2000

  www.GTSI.com

May
12, 2005

BY EDGAR,
FACSIMILE AND FEDERAL EXPRESS

Craig Wilson, Senior Assistant Chief
Accountant

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0406

  Re:

  GTSI Corp.’s Form 10-K for
  the Fiscal Year

  Ended December 31, 2004,
  File No. 000-19394

Dear Mr. Wilson:

On behalf of GTSI Corp. (“GTSI” or the “Company”),
I am providing this letter in response to the comments of the Commission’s
staff set forth in your letter dated April 28, 2005 regarding the Company’s
annual report on Form 10-K for the fiscal year ended December 31, 2004
(File No. 000-19394) filed with the Commission on March 16, 2005 (the “2004
Form 10-K”). To aid in the staff’s review, I have repeated the staff’s comments
followed by the Company’s responses.

Item 1.
Business

Business Strategy, p. 4

1.  We
note that your disclosure in this section indicates that you plan to “[d]ouble
the revenue base of GTSI from $1 billion to $2 billion” over the next three
years primarily through “organic measures, supplemented by strategic
acquisitions,” and that you have included similar disclosure in MD&A. As
your sales grew only 12.8% during 2004, it is unclear how you plan to achieve
such revenue growth. Accordingly, please provide supplemental support for this
statement and revise the disclosure in your filing to better explain how you
plan to double your revenues over the next three years.  For example, what are the “organic measures”
you plan to take and how will such measures affect revenues? Do you have any
current plans regarding specific strategic acquisitions? Please revise and advise accordingly.

The Company provided disclosure throughout the 2004 Form 10-K to
explain the Company’s business strategy and believes the disclosure is
sufficient.  Such business strategy
disclosure in the 2004 Form 10-K includes the following:

p.4  ”We
plan to continue to increase our work force to take advantage of the growing
government IT market. Our management has undertaken a number of initiatives
consistent with this revenue
and earnings growth

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strategy
(e.g., hiring and training additional personnel, creating a centralized pricing
organization, creating a centralized purchasing organization and implementing
the final phase of our new ERP system).”

p.5  ”[W]e
plan to increase employee productivity through training, use of the improved
technology from our new Enterprise
Resource Planning (“ERP”) system, and a heightened focus on our customer
relationship management (“CRM”) initiatives.”

p.10
Marketing and Sales “Our sales organization is focused on understanding
the current and emerging needs of our customers and to provide products,
services and bundled solutions to meet those needs. Our sales organization
continues to provide deep
coverage for existing customers while expanding sales coverage to focus on new
accounts and new product and service offerings to current customers. Our
Customer Teams work closely with our Enterprise Technology Practices to best meet the requirements of
our customers.”

p.18  MD&A  “We
expect to expand our sales from lease arrangements for IT products and
solutions in 2005.  We have essentially
completed the build-out of our ERP system. After full testing and retesting,
extensive training and documentation of new work processes for SOX compliance,
we plan to implement the final phase of our ERP capabilities throughout GTSI in
the second quarter of 2005.

In addition to the implementation of the final phase
of our ERP system, several other initiatives are underway to position GTSI to
reach our strategic plan goal of increased productivity including proactive
supply-chain management; customer, deal, and vendor profitability assessments;
and order management improvements. Management is also evaluating various CRM
solutions…”

p.21  MD&A “We
provide a table showing the trend in increased sales from services from $13.8
million in 2002 to $19.7 million in 2004. And in the narrative on page 22 we
state “Sales of services increased 23.9% from 2003 to 2004 to $19.7 million. We
intend to grow our service revenue at a similar rate in 2005.”

p.25  Seasonal Fluctuations “While sales
to the U.S. Government are usually weaker in the first and second quarter and
stronger in the third and fourth quarter, our Selling, General &
Administrative expenses are more level throughout the year. As such, first and second quarter earnings are typically well below those of the third
and fourth quarters.”

In summary of the above-referenced disclosure
in the 2004 Form 10-K, the organic measures the Company has taken to increase
its revenue base include, among other things, increasing headcount by 20% in 2004,
predominantly in the Company’s sales and marketing organizations.  Each salesperson and respective sales team are

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allocated quotas
based on the Company’s revenue and margin goals.  It is management’s belief that the addition
of sales professionals will produce greater sales dollars in the future as the
Company will have more representation in a growing government IT marketplace.
The Company invested in additional personnel during 2004 and anticipates stronger
revenue growth during the Company’s seasonally strong third and fourth
quarters.

The Company also completed the build-out of a
supply chain management ERP system which was implemented during April 2005.
Management believes that this infrastructure investment will provide the
foundation and resources to support increased delivery and shipment of products
to the Company’s customers. Management anticipates the ERP system decreasing
the lag time between order placement and shipment.

The additional measures the Company plans to
take during the next few years to expand revenue include implementing and
utilizing an enhanced customer relationship management tool (“CRM”) and
expanding the volume of services the Company provides.  Utilization of a robust CRM platform is
expected to allow the Company to more effectively cross-sell and up-sell
additional products, services and warranties based on its customers’ needs and
ordering patterns.  Currently, revenue
from providing services comprises less than 2% of the Company’s sales. The
Company plans to increase the percentage of sales from services, which are
typically billed at a higher gross margin rate than products.

The Company’s analysis of the Federal, State
and Local Governments indicates IT budgets totaling $120 billion.  In addition, the Bush administration has
requested a 7% increase in IT spending.
The Company’s $1 billion market share represents less than 1% of this
total budget.  Even an increase to 2% in
the Company’s market share of the government IT budget would enable GTSI to
reach its strategic revenue goal.

Regarding revenue growth from acquisitions,
while at this time the Company does not have plans regarding specific
acquisitions if management becomes aware of an accretive opportunity which could
expand revenue and be effectively integrated with the organization, management
is prepared to evaluate and act.

The Company developed a financial plan in
2004 to support its revenue goal of $2 billion which was reviewed and
considered by the Company’s Board of Directors. The Company has periodically
updated this financial plan and presented such revisions to the Board of
Directors on several occasions.

The Company will modify future Commission
filings to include more detail and supplemental support regarding its business
strategy, as the Commission staff suggests. The Company will consolidate the
supporting detail within subsequent periodic filings with the Commission into a
more concise Outlook section of the MD&A similar to the following:

It is our belief
that our investment in the addition of sales professionals will increase
revenues incrementally as the members of our sales force derive productivity
and increase our representation in a growing

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government IT marketplace.  We expect our
infrastructure investment in our ERP system will provide the foundation and
resources necessary to support increased delivery and shipment of products to
our customers, reducing the lag time between order placement and shipment.  Utilization of a robust CRM platform is
expected to allow us to more effectively cross-sell and up-sell additional
products, services and warranties based on our customers’ needs and ordering
patterns.  We plan to continue to
increase the percentage of our sales from providing services.

Contracts, p. 6

2.
Explain the nature of the “administrative fee(s)” that are levied by
various government agencies on purchases made by departments outside of the
agency that awarded the contract. Quantify the amount [of] fees that are
collected by you and remitted to the respective agency for the periods
presented and explain your revenue recognition policies associated with these
fees. In your response, address the criteria outlined in EITF 99-19. If material,
revise your revenue recognition accounting policy to address your accounting
for these fees.

Most of the Company’s customers are
departments and agencies of the U.S. Federal government.  The Company’s customers purchase products
from GTSI utilizing an approved government contract vehicle.  The majority of the contract vehicles GTSI
holds have a contracting government agency, such as NASA or the Army.  If another government agency or department
wants to use the contract vehicle sponsored by, for example, NASA to purchase
products from GTSI, a portion of the purchase price represents an
administrative fee due to NASA for that ability. When GTSI receives payment
from the customer, the Company remits the administrative fee portion to NASA.

During the years ended December 31,
2004, 2003 and 2002, GTSI collected and has paid (or will be paying)
administrative fees based on the terms of the contract to the respective
governmental agencies totaling $5.7 million, $6.4 million and $5.7 million,
respectively.  The recording of these
fees is similar to sales tax payable. The Company acts as a collection vehicle
for the contracting government agency neither retaining any of the collected
fees nor recognizing any revenue (or expense) for managing this process on behalf
of the contracting agency.  Accordingly,
the Company does not recognize revenue on these transactions and EITF 99-19 is
not applicable because these administrative fees are purely pass-through items
for the Company.

Notes to Consolidated Financial
Statements

Note 7.
Accounts Payable, p. 41

3.
Tell us more about the obligations that you were judicially released
from upon the expiration of the statute of limitations in 2004. Explain the
nature of the obligations and the transactions under which you initially became
obligated, including the respective counterparties, and describe the statue of
limitations you refer to. Provide us any additional supplemental information
surrounding these obligations that will support your conclusions that you were
judicially released from the obligations.

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[FOIA Confidential Treatment pursuant to 17
C.F.R. §200.83 has been requested by GTSI in respect of its response to this
comment.]

4.
Also tell us more about the aged accrued payables that management
concluded were “no longer valid liabilities”. Explain the nature of the
obligations and the transactions under which you initially become obligated,
including the respective counterparties. Clarify whether these were ever ‘valid
liabilities’. If so, explain why it was appropriate to derecognize these
liabilities in accordance with SFAS 140. Explain the timing of the reversal,
and discuss why it was appropriate to derecognize these payables during 2004.

The accounts payable line on the Company’s
balance sheet includes a number of accounts, including trade payables, income
taxes payable, administrative fees payable, customer refunds and an account the
Company calls Receivers Payable. The $2.5 million reversal disclosed in Note 7
resulted from reconciliations of Receivers’ Payable account during the third
and fourth quarters of 2004. Receivers Payable is used to accrue a payable for
products received in inventory for which the vendor’s invoice has not yet been
received.  The accrual is recorded for
the amount of the purchase order.  When
the invoice from the respective vendor is received, Receivers Payable is
debited for the amount of the invoice and trade payables is
credited. Frequently the amount of the invoice does not exactly match the
amount on the purchase order due to vendor price changes, special monthly
promotions, other pricing variances and freight charges. This account is
reconciled on a monthly and quarterly basis and variances are researched. In
cases where the invoice received is for less than the purchase order, it was
management’s policy to leave the outstanding credit “open” in the account for
two years to allow for subsequent invoices to be received.

In the third quarter of 2004 the Company
performed an analysis of Receivers Payable activity during the period 2000 to
2004 pursuant to its SOX 404 initiatives.
This analysis indicated that invoices were rarely received for accruals
aged greater than one year. Based upon this finding, Management decided that
recent experience indicated that a one year period was a better estimate and
revised its policy to only leave credits “open” for one year with quarterly
true-ups performed on a year-over-year basis.
This policy change, which was in place prior to 12/31/04, resulted in a
change in estimate of $2.5 million. This amount, which has no material impact
on prior quarters’ financial results, comprises purchase orders to over 150
vendors on almost 1,000 transactions, with variances ranging from $1 to
$300,000.

At the time inventory was received,
management considered all of these valid liabilities. Accruals were recorded
based upon purchase order amounts which represented amounts due to vendors for
inventory received in the Company’s warehouse based on their most recent price
lists.  (These adjustments represented
less than 2% of GTSI’s accounts payable balance at December 31, 2004 and
2003.)

To clarify, the Receivers Payable adjustments
discussed above were recorded as a change in estimate, and not derecognized as
the extinguishment of a liability in accordance with SFAS 140.

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5.
Revise Selected Financial Data to briefly describe and/or cross
reference to a discussion of the reversal of accounts payable and the material
effect that reversal had on the comparability of the information presented.

In the Company’s Selected Quarterly Financial Data disclosure in Note
16 on page 48, the Company provided a cross reference to Note 7 of the
financial statements regarding the third quarter of 2004 financial data (period
in which the reversal occurred).  As
such, the Company does not believe an amendment to our 2004 Form 10-K is
required. However, in future annual report filings with the Commission, the
Company will expand the cross reference to address the effect on comparability
between periods as follows:

Our results of operations for 2004 include
the effects of the derecognition of aged accrued payables of $10.1 million
during the third quarter, and the reversal of accounts payable of $0.7 million
in the third quarter and $1.8 million in the fourth quarter as discussed in
Note 7 to the consolidated financial statements.

Expand the Overview section and/or include a discussion of net income and operating
income in MD&A to discuss the significant impact the reversal of accounts
payable had on your operating income and net income. In this regard, it appears
that the annual and quarterly trends in your operating income and net income
would have been materially different had you not derecognized these accounts
payable in the respective periods.

The Company d