SecProbe.io

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                                                April 20, 2005

VIA EDGAR
---------

Mr. Thomas Flinn
Staff Accountant
Division of Corporation Finance
Mail Stop 0409
450 Fifth Street, N.W.
Washington, DC 20549

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

Dear Mr. Flinn:

The following are the Company's responses to the comments included in your
letter dated April 11, 2005 regarding the above-captioned filing. For ease of
reference the questions have been restated above each response.

How Management Evaluates Results of Operations, Appendix A Page 4
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   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?

One of the most significant components of management's evaluation of results of
operations is its determination of the Company's ability to pay quarterly
dividends to its shareholders. This evaluation includes a review of cash flow
from each investment (defined by management as lease revenues less
property-level debt service regardless of its GAAP classification). These
evaluations, therefore, are performed on a pro-rata basis and all of the
Company's unconsolidated properties are controlled by related parties who are
managed by the same advisor as the Company. The Company underwrites its
investments in properties primarily based on the underlying credit of the
lessees of the properties. We believe that providing a chart of lease revenues
by investment in descending order enables the investor to see the Company
through the eyes of management and also enables the investor to gain an
understanding of the Company's portfolio diversification and the credit
concentration from its largest investments.

The chart of lease revenues by investment indicates which investments are not
consolidated. Additionally, the Company provides a reconciliation that
segregates lease

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revenue as shown on the income statement from lease revenues associated with
unconsolidated properties. Pro-rata revenues are clearly labeled in the
reconciliation.

The Company believes that eliminating this disclosure would result in investors
having less information about how management in fact evaluates results of
operations.

Footnote 18 - Subsequent Events, Page 33
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   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."

The Company owns a property located in Piscataway, New Jersey that was formerly
net leased to Rheometric Scientific, Inc. In January 2003, pursuant to
completion of the sale of Rheometric's business, the lease agreement was
terminated and two successor companies to Rheometric leased a portion of the
vacant space for one year. Upon termination of these leases in January 2004, the
tenants vacated the premises and the entire property was unoccupied.

The Company actively marketed the property to prospective tenants for leasing
opportunities after the termination of the Rheometric lease and throughout the
period up to February 2005. The Company's intent was to hold the property for
long- term investment, in keeping with its objective of holding investment
properties for extended periods of time. During the period from the termination
of the Rheometric lease to and including December 31, 2004, the Company
evaluated the property for potential impairment as a held for use property, in
accordance with the provisions of FAS 144. The undiscounted cash flow tests
performed reflected that the carrying value of the property was recoverable and
no impairment charge was required.

In February 2005 the Company received an offer to purchase the property for
approximately $3.1 million. In light of the expected disproportionate amount of
management time that long-term lease-up of this relatively small property to the
overall portfolio would entail and with substantial costs incurred to carry the
property during those periods, in February 2005 the Company decided that a sale
of the property would be in its best interests in order to conserve cash flow
and realize the value of its investment. Accordingly, on February 11, 2005 the
Company approved a plan of sale and reclassified the property to held for sale.
The carrying value of the property was reduced to its estimated fair value of
approximately $2.9 million (representing the sale price less estimated costs to
sell) and an impairment charge of approximately $2.745 million was recorded for
the quarter ended March 31, 2005. The receipt of the purchase offer in February
2005 caused the Company to re-evaluate its expected holding period for this
property resulting in the adoption of the plan of sale and recognition of the
impairment charge in this period.

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The company also makes the following statements in response to your letter:

   o    The company is responsible for the adequacy and accuracy of the
        disclosure in the filings;

   o    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

   o    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 questions regarding the responses to your comments please call
me at 212-492-1114. Thank you for your prompt attention to this matter.

                                                     Sincerely,

                                                     /s/ John J. Park
                                                         ----------------------
                                                         John J. Park
                                                         Managing Director and
                                                         Chief Financial Officer

cc:  Cicely D. Luckey
     James Barnes, Esq.

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