SecProbe.io

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                                                                    May 18, 2005

VIA EDGAR
---------

Mr. Thomas Flinn
Staff Accountant
Division of Corporation Finance
Mail Stop 4561
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 is the Company's response to the comments included in your letter
dated May 5, 2005 regarding the above-captioned filing. For ease of reference we
have included the original question above our response.

How Management Evaluates Results of Operations, Appendix A Page 4
-----------------------------------------------------------------
1.       We have considered your response to our previously issued comment 1.
         Since you do not control the unconsolidated properties, we continue to
         object to a presentation in which you aggregate revenue from
         consolidated and unconsolidated properties to derive a total amount of
         lease revenues. We would not object to a presentation of lease revenues
         for your consolidated properties separately from those of your
         unconsolidated properties provided the information is made in the
         context of discussing how you derive income from your unconsolidated
         properties. Please revise your presentation in future filings as
         appropriate.

In accordance with your recommendation, the Company will revise its
presentation for future filings, beginning with its 2005 first quarter filing,
(as filed on May 10, 2005) to separately disclose lease revenues from the
Company's consolidated and unconsolidated properties.

If you have any questions regarding the Company's response to your comments
please call me at 212-492-1166. Thank you for your prompt attention to this
matter.

                                            Sincerely,

                                           /s/ Claude Fernandez
                                           --------------------
                                               Claude Fernandez
                                               Managing Director and
                                               acting Chief Financial Officer

cc:  Cicely D. Luckey
     James Barnes, Esq.

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