SecProbe.io

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                                                     August 9, 2005

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

         RE:      Van Kampen Advantage Municipal Income Trust II
                  Form N-14 (File No. 333-126299)

Dear Mr. Greene:

         On June 30, 2005, Van Kampen Advantage Municipal Income Trust II (File
No. 811-07868) filed a registration statement on Form N-14 with respect to the
proposed reorganization of Van Kampen Municipal Opportunity Trust II and Van
Kampen Value Municipal Income Trust into Van Kampen Advantage Municipal Income
Trust II (the "Proposed Reorganization"). Following our telephone conversation
of July 21, 2005, I write in response to your request that we address, with
respect to the Proposed Reorganization, any issues raised by the staff of the
Securities and Exchange Commission in North American Security Trust (publ.
avail. Aug. 5, 1994) ("North American").

         In North American, North American Security Trust ("NAST"), a registered
investment company with a number of separate investment portfolios organized as
series of NAST, had reorganized three existing funds into a newly created fund,
and NAST sought the staff's position on whether the newly created fund could
advertise the performance record of one of the predecessor target funds. This
fact pattern materially differs from the fact pattern presented in the Proposed
Reorganization of Van Kampen Municipal Opportunity Trust II (the "Municipal
Opportunity Trust II") and Van Kampen Value Municipal Income Trust ("Value
Municipal Income Trust") (collectively, the "Target Funds") into Van Kampen
Advantage Municipal Income Trust II (the "Acquiring Fund"). In North American,
the acquiring fund was a newly created fund with no historical performance
record

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Larry Greene
August 9, 2005
Page 2

that was seeking to advertise the historical performance of one of the three
target funds. In the Proposed Reorganization, however, the Acquiring Fund is an
existing, operating fund which intends going forward to advertise only its own
historical performance and does not seek to advertise performance information of
the Target Funds. Thus, North American on its face does not apply to the present
situation.

         Notwithstanding this conclusion, we also believe that the factors
enumerated by the staff in North American support the conclusion that the
surviving Acquiring Fund in the Proposed Reorganization should continue to use
its historical performance record going forward. In North American, the staff
stated that the surviving fund in the reorganization could carry forward the
performance record of the predecessor target fund that most "closely resembles"
the surviving fund. The staff indicated that in determining which predecessor
fund most closely resembles the surviving fund, the following factors, among
others, should be considered: 1) the similarity of the investment advisers of
the funds; 2) the investment objectives, policies and restrictions of each fund;
3) the net asset level of each fund; 4) the expense structure and expense ratio
of each fund; and 5) the portfolio composition of each fund. We address each of
these factors in turn below:

         1) The investment adviser to each Fund is Van Kampen Asset Management
(the "Adviser"). Each Fund is managed by the same members of the Adviser's
Municipal Fixed Income team. The surviving fund will continue to be managed by
the same members of this team.

         2) Each Fund seeks to provide common shareholders with a high level of
current income exempt from federal income tax, consistent with preservation of
capital, by investing substantially all of its assets in municipal securities
rated investment grade at the time of investment. The surviving fund will
continue to pursue this investment objective.

         While the Funds' other investment policies and investment restrictions
are similar, the surviving fund will continue to comply with the Acquiring
Fund's investment policies and investment restrictions.

         3) As of January 31, 2005, Municipal Opportunity Trust II had net
assets (including assets attributable to preferred shares) of approximately
$294.7 million, Value Municipal Income Trust had net assets (including assets
attributable to preferred shares) of approximately $599.3 million, and the
Acquiring Fund had net assets (including assets attributable to preferred
shares) of approximately $203.2 million.

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Larry Greene
August 9, 2005
Page 3

         4) The expense structures of the Funds are identical. Each Fund pays
the Adviser a monthly management fee at the annual rate of 0.55% of such Fund's
average daily net assets, including assets attributable to preferred shares, and
the surviving fund will maintain this expense structure.

         5) Under normal market conditions, each Fund invests substantially all
of its assets in municipal securities rated investment grade at the time of
investment. The portfolio composition of the surviving fund will continue to be
that of the Acquiring Fund.

         After completion of the Proposed Reorganization, the surviving fund
will closely resemble the Acquiring Fund. Although the Acquiring Fund is not the
largest fund in terms of net assets, the surviving fund will be managed by the
Acquiring Fund's portfolio management team, will maintain the Acquiring Fund's
expense structure, will continue to pursue the Acquiring Fund's investment
objective and policies and will hold a portfolio that is substantially similar
to that of the Acquiring Fund. Accordingly, it is appropriate for the surviving
fund to carry forward the historical performance record of the Acquiring Fund.

         Should the staff have any additional questions regarding this issue,
please contact the undersigned at (312) 407-0940 or Charles B. Taylor at (312)
407-0863.

                                    Sincerely,

                                    Christopher M. Rohrbacher

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