SecProbe.io

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      April 11, 2005

Mail Stop 0409 via U.S. Mail and Fax (212) 492-8922

Mr. John J. Park
Chief Financial Officer
Corporate Property Associates 12, Inc.
50 Rockefeller Plaza
New York, New York 10020

Re:	Corporate Property Associates 12, Inc.
	Form 10-K for the year ended December 31, 2004
      File No. 033-68728

Dear Mr. Park:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.

      Where indicated, we think you should revise your documents
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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

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

How Management Evaluates Results of Operations, Appendix A Page 4
1. In your discussion of how management evaluates the source of
lease
revenues, we note that you are aggregating revenues from
consolidated
properties with those of unconsolidated properties.  Given the
revenue amounts from your unconsolidated properties are not
derived
from the revenue amounts reported in your GAAP financial
statements,
how are you able to reconcile these amounts under Item 10(e) of
Regulation S-K?  Since you do not control the unconsolidated
properties, what consideration was given to separately presenting
information from your consolidated and unconsolidated properties
to
provide transparency?

Financial Statements and Notes

Footnote 18 - Subsequent Events, Page 33
2. We note that you are recording an impairment charge of
approximately $2,745,000 in the quarter ending March 31, 2005 for
a
property located in Piscataway, New Jersey.  Please advise why
there
was no impairment charge for this property in 2004 as you state
"management approved a plan to sell a property located in
Piscataway,
New Jersey that has been vacant since February 2004."

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your proposed revisions that
keys
your responses to our comments and provides any requested
supplemental 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
responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain 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 filings;

*
staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Tom Flinn, Staff Accountant, at (202) 824-
5225
or the undersigned at (202) 942-1975 if you have questions.

						Sincerely,

Cicely D. Luckey
Accounting Branch Chief

Corporate Property Associates
April 11, 2005
Page 3

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