SecProbe.io

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April 8, 2005

Mail Stop 0409

VIA U.S. MAIL AND FAX (310) 248-2222

Mr. David E. Hamer
Controller and Chief Accounting Officer
G&L Realty Corp.
439 N. Bedford Drive
Beverly Hills, CA  90210

Re:	G&L Realty Corp.
Form 10-K for the year ended December 31, 2004
File No. 001-12566

Dear Mr. Hamer:

      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.  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.

Form 10-K for the year ended December 31, 2004

Financial Statements and Notes

Consolidated Statement of Operations

1. We note that you did not present the spin-off of your skilled
nursing and assisted living facilities as discontinued operations.
Tell us how you considered the relevant guidance in SFAS 144 and
EITF
03-13 in reaching this conclusion.  Supplementally, show us how
you
will revise your disclosure in future filings to describe the
types
of continuing involvement, if any, that you will have after the
spin-
off transaction.
*  *  *  *

	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 Josh Forgione, at (202) 824-5464, or me, at
(202) 942-1960, if you have questions. Please respond to the
comments
included in this letter within ten business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

							Sincerely,

Linda van Doorn
      Senior Assistant Chief Accountant

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G&L Realty Corp.
April 8, 2005
Page 1

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