SecProbe.io

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                    Skadden, Arps, Slate, Meagher & Flom LLP
                              333 West Wacker Drive
                             Chicago, Illinois 60606

                                                                  August 9, 2005

Mr. Larry Greene
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549

                        Re: Van Kampen Municipal Opportunity Trust--
                        Registration Statement on Form N-14
                        (the "Registration Statement")
                        (File Nos. 333-126305 and 811-06567)

Dear Mr. Greene:

         Thank you for your telephonic comments regarding the Registration
Statement on Form N-14 for Van Kampen Municipal Opportunity Trust (the
"Acquiring Fund" or the "Registrant") filed with the Securities and Exchange
Commission (the "Commission") on June 30, 2005 in connection with the proposed
reorganization (the "Reorganization") of Van Kampen Advantage Municipal Income
Trust (the "Target Fund") into the Acquiring Fund. On behalf of the Acquiring
Fund, we have summarized your comments to the best of our understanding, below
which we have provided our response to those comments. We have not included
comments which we resolved in the course of our conference call with you. Where
changes were necessary in response to your comments, they are reflected in
Pre-Effective Amendment No. 1 to the Acquiring Fund's Registration Statement on
Form N-14, which will be filed on or about August 9, 2005. The Target Fund and
the Acquiring Fund are referred to herein collectively as the "Funds."

COMMENTS TO THE JOINT PROXY STATEMENT/PROSPECTUS

COMMENT 1.        UNDER "QUESTIONS & ANSWERS," IN THE RESPONSE TO THE SECOND
                  QUESTION, REVISE THE DISCLOSURE TO MORE FULLY EXPLAIN THE
                  REASONS FOR THE PROPOSED REORGANIZATION.

Response 1.       The Funds respectfully submit that they have adequately
                  conveyed the reasons for the proposed Reorganization. The
                  Funds respond to that question as follows:

                  The Board of Trustees of each Fund has determined that the
                  Reorganization will benefit common shareholders of the Target
                  Fund and the Acquiring Fund. The Target Fund and the Acquiring
                  Fund are similar. Each Fund seeks to provide common
                  shareholders with a high level of current income exempt from
                  federal income tax, consistent with preservation of capital.
                  Each Fund invests primarily in municipal securities rated
                  investment grade at the time of investment. Each Fund is
                  managed by the same investment advisory personnel. After the
                  Reorganization, it is anticipated that common shareholders of
                  each Fund will experience a reduced annual operating expense
                  ratio, as certain fixed administrative costs will be spread
                  across the combined fund's larger asset base.

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                  This disclosure notes that the Funds pursue substantially
                  similar investment objectives and strategies and are managed
                  by the same investment advisory personnel. These facts serve
                  as important background for the primary reason for the
                  Reorganization--the anticipated reduced annual operating
                  expense ratio for common shareholders of each Fund. Given that
                  the Funds pursue substantially similar investment objectives
                  and strategies and are managed by the same investment advisory
                  personnel, common shareholders of each Fund should find the
                  anticipated reduced annual operating expense ratio as a
                  compelling reason to support the Reorganization of the Funds.

COMMENT 2.        UNDER THE "FEE, EXPENSE AND DISTRIBUTIONS ON PREFERRED
                  SHARES TABLE FOR COMMON SHAREHOLDERS OF THE FUNDS," THE FUNDS
                  MAY DELETE ALL REFERENCES TO ANY FEE DESCRIPTIONS FOR WHICH NO
                  CLASS OF SHARES PAYS SUCH FEES.

Response 2.       The Funds acknowledge the comment and opt to continue to show
                  these captions.

COMMENT 3.        UNDER "PROPOSAL 1--COMPARISON OF THE FUNDS--OTHER
                  INVESTMENT PRACTICES AND POLICIES--STRATEGIC TRANSACTIONS,"
                  PROVIDE ADDITIONAL DISCLOSURE REGARDING EACH FUND'S COMPLIANCE
                  WITH APPLICABLE REGULATORY REQUIREMENTS WHEN IMPLEMENTING
                  STRATEGIC TRANSACTIONS.

Response 3.       Each Fund may engage in certain strategic transactions,
                  such as put and call options, financial futures contracts and
                  interest rate transactions such as swaps, caps, floors or
                  collars. The Funds disclose that they "compl[y] with
                  applicable regulatory requirements when implementing these
                  strategies, techniques and instruments." This general
                  disclosure provides the Funds with flexibility to adjust to
                  changes in applicable law, rules, regulations or exemptive
                  relief. The Funds acknowledge the Staff's comment but do not
                  believe that additional disclosure is necessary.

COMMENT 4.        UNDER "PROPOSAL 1--COMPARISON OF THE FUNDS--OTHER
                  INVESTMENT PRACTICES AND POLICIES--INVESTMENT RESTRICTIONS,"
                  WITH RESPECT TO THE SECOND INVESTMENT RESTRICTION, NOTE THE
                  LOCATION OF THE DESCRIPTION OF EACH FUND'S ABILITY TO INVEST
                  MORE THAN 25% OF ITS TOTAL ASSETS IN A PARTICULAR SEGMENT OF
                  THE MUNICIPAL SECURITIES MARKET, AND EXPLAIN WHETHER SUCH
                  DESCRIPTION IS ALSO A FUNDAMENTAL POLICY.

Response 4.       The Funds have made the requested changes.

COMMENT 5.        UNDER "PROPOSAL 1--COMPARISON OF THE FUNDS--OTHER
                  INVESTMENT PRACTICES AND POLICIES--INVESTMENT RESTRICTIONS,"
                  REVISE THE THIRD INVESTMENT RESTRICTION SUCH THAT "BORROWINGS"
                  IS NOT DEFINED BY REFERENCE TO THE FOURTH INVESTMENT
                  RESTRICTION.

Response 5.       The Funds acknowledge the comment, but respectfully submit
                  that investment restrictions may not be revised without a
                  shareholder vote.

COMMENT 6.        UNDER "PROPOSAL 1--INFORMATION ABOUT THE
                  REORGANIZATION--MATERIAL U.S. FEDERAL INCOME TAX CONSEQUENCES
                  OF THE REORGANIZATION," PROVIDE DISCLOSURE REGARDING CAPITAL
                  LOSS CARRYFORWARDS, IF APPLICABLE.

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Response 6.       The Funds respectfully submit that the rule applicable to
                  capital loss carryforwards is not material with respect to the
                  Reorganization and therefore no such disclosure is necessary.

COMMENT 7.        UNDER "OTHER INFORMATION--SHAREHOLDER PROPOSALS," PROVIDE
                  THE DISCLOSURE REQUIRED BY RULE 14A-8(E) OF REGULATION 14A.

Response 7.       The Funds have added the requested disclosure.

COMMENTS TO THE STATEMENT OF ADDITIONAL INFORMATION (SAI)

COMMENT 8.        UNDER "TRUSTEES AND OFFICERS--BOARD COMMITTEES," INDICATE
                  WHETHER THE MEMBERS OF THE BOARD'S BROKERAGE AND SERVICES
                  COMMITTEE ARE INTERESTED TRUSTEES.

Response 8.       The first paragraph of that section reads as follows:

                           "The Board of Trustees has three standing committees
                           (an audit committee, a brokerage and services
                           committee and a governance committee). Each committee
                           is comprised solely of 'Independent Trustees,' which
                           is defined for purposes herein as trustees who: (1)
                           are not 'interested persons' of the Fund as defined
                           by the 1940 Act and (2) are 'independent' of the Fund
                           as defined by the New York Stock Exchange, American
                           Stock Exchange and Chicago Stock Exchange listing
                           standards."

                  Thus, the Funds do not believe that additional disclosure is
                  necessary.

COMMENT 9.        IN THE FIFTH PARAGRAPH UNDER "INVESTMENT ADVISORY
                  AGREEMENT," DISCUSS THE FACTORS INVOLVED IN DETERMINING THE
                  APPROVAL OF THE INVESTMENT ADVISORY AGREEMENT.

Response 9.       The Funds respectfully submit that they have satisfied the
                  existing disclosure requirements regarding approval of
                  advisory contracts required under Form N-14. Form N-14 (Items
                  12(b) and 13(b)) requires the Funds to furnish in the SAI the
                  information called for under Item 18.13 of Form N-2.
                  Investment Company Act Release No. 26486 (June 23, 2004) (the
                  "Release") removes Item 18.13 of Form N-2 effective January
                  31, 2006 and adds new disclosure regarding approval of
                  advisory contracts to shareholder reports.

                  The Funds respectfully submit that they are not yet obligated
                  to provide this new disclosure in their shareholder reports.
                  The Release adds subsection (e) to Item 24.6 of Form N-2,
                  which applies only "[i]f the Registrant's board of directors
                  approved any investment advisory contract during the
                  Registrant's most recent fiscal half-year." Each Fund's most
                  recent fiscal half-year ended April 30, 2005, which preceded
                  the May 25-26, 2005 Board meeting at which the investment
                  advisory contract for each Fund was renewed. Since the Board
                  had not approved the investment advisory contracts pursuant to
                  the revised disclosure rules prior to April 30, 2005, the
                  Funds were not required to provide the new disclosure in their
                  most recent shareholder reports. Although the Release states
                  that "[p]rior to January 31, 2006, a fund may omit disclosure
                  in its SAI with respect to any board

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                  approval of an investment advisory contract if it has
                  previously provided the required disclosure with respect to
                  that board approval in a shareholder report," since none of
                  the Funds has yet been obligated to provide the new disclosure
                  in its shareholder reports, the Funds have provided the
                  disclosure currently required by Item 18.13 of Form N-2.

                  The new disclosure requirements also apply to "all proxy
                  statements filed on or after October 31, 2004," and the N-14
                  serves as a proxy statement for the Acquiring Fund with
                  respect to the issuance of additional common shares in
                  connection with the Reorganizations. However, the Funds
                  respectfully submit that they are not obligated to provide
                  this new disclosure. The Release adds new disclosure to Item
                  22(c)(11) of Schedule 14A; Item 22(c), though, applies only
                  "[i]f action is to be taken with respect to an investment
                  advisory contract." Accordingly, since the Acquiring Fund is
                  not taking action with respect to an investment advisory
                  contract, the new disclosure is not required.

COMMENT 10.       UNDER "FUND MANAGEMENT," PROVIDE THE DISCLOSURE REQUIRED
                  BY ITEM 21.2 OF FORM N-2 WITH RESPECT TO COMPENSATION.

Response 10.      The Funds respectfully submit that they have satisfied the
                  existing disclosure requirements regarding portfolio manager
                  compensation. Item 21.2 requires disclosure of "the structure
                  of, and the method used to determine, the compensation of each
                  Portfolio Manager." The Funds' investment adviser has created
                  a structure and method for compensating portfolio managers
                  which is fully described in the SAI. To the extent that the
                  Funds disclosed any additional information regarding the
                  structure and method for compensating its portfolio managers,
                  they would risk the possibility that the value of compensation
                  would be disclosed, a result that is specifically disclaimed
                  by Item 21.2 ("[t]he value of compensation is not required to
                  be disclosed under this Item").

COMMENT 11.       WITH RESPECT TO THE PRO FORMA FINANCIAL STATEMENTS IN
                  APPENDIX H TO THE SAI, DISCLOSE THE EXTENT TO WHICH SECURITIES
                  OF THE TARGET FUND MAY BE SOLD IN CONNECTION WITH THE PROPOSED
                  REORGANIZATION.

Response 11.      In the second introductory paragraph to the pro forma
                  financial statements, the Funds have noted the following:

                           There is no guarantee that the portfolio of
                           investments of the surviving entity on the closing
                           date of the transaction will match the Pro Forma
                           Portfolio of Investments presented herein. All or a
                           portion of the securities acquired in the transaction
                           could be sold by the surviving entity; however, there
                           is no plan or intention to sell securities acquired
                           in the transaction other than in the ordinary course
                           of business.

ACCOUNTING COMMENTS

COMMENT 12.       WITH RESPECT TO THE PROPOSED REORGANIZATION, ADDRESS ANY
                  ISSUES RAISED BY THE STAFF OF THE SECURITIES AND EXCHANGE
                  COMMISSION IN NORTH AMERICAN SECURITY TRUST (PUBL. AVAIL. AUG.
                  5, 1994) ("NORTH AMERICAN").

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Response 12.      The Funds' analysis of North American has been prepared and
                  filed as a separate correspondence.

COMMENT 13.       EXPLAIN SUPPLEMENTALLY THE BASIS FOR THE CHOICE OF JANUARY
                  31, 2005 AS THE DATE FOR THE PRO FORMA FINANCIAL STATEMENTS
                  ATTACHED AS APPENDIX H TO THE SAI.

Response 13.      Rule 11-02(c) of Regulation S-X governs the periods to be
                  presented with respect to pro forma financial information.
                  Rule 11-02(c)(1) requires that a pro forma financial
                  information be prepared "as of the end of the most recent
                  period for which a consolidated balance sheet of the
                  registrant is required by Rule 3-01." Rule 3-01(g) refers
                  registered management investment companies to Rule 3-18 in
                  lieu of Rule 3-01. Rule 3-18(c) states:

                           If the most current balance sheet or statement of
                           assets and liabilities in a filing is as of a date
                           245 days or more prior to the date the filing is
                           expected to become effective, the financial
                           statements shall be updated with a balance sheet or
                           statement of assets and liabilities a