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Mail Stop 4561
      October 28, 2005

Chad C. Braun
Chief Financial Officer
Amreit
8 Greenway Plaza, Suite 1000
Houston, TX 77046

	Re:	Amreit
		Form 10-K for Fiscal Year Ended December 31, 2004
		Form 10-Q for Fiscal Quarter Ended March 31, 2005
		File No. 0-28374

Dear Mr. Braun:

      We have reviewed your response letter dated August 31, 2005
and
have the following additional comments.  In our comments, we ask
you
to provide us with additional 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 Fiscal Year Ended December 31, 2004

Item 6 - Selected Financial Data, page 16

1. We have considered your response to our previous comment one
and
continue to believe that adjusting FFO for impairment losses is
not
consistent with Item 10(e) of Regulation S-K.  Please revise
accordingly in future filings.

2. As it relates to your presentation of deferred merger charges,
we
note that while it was a single event that gave rise to the
charge,
the impact to the financial statements has been recurring.
However,
if you choose to adjust FFO for this amount going forward on the
basis that the impact will disappear in future filings, then you
should include these representations in your document.  Further
you
should provide robust disclosure addressing the following:
* The manner in which management uses the non-GAAP measure to
conduct
or evaluate its business
* The economic substance behind management`s decision to use the
measure;
* The material limitations associated with use of the non-GAAP
financial measure as compared to the use of the most directly
comparable GAAP financial measure;
* The manner in which management compensates for these limitations
when using the non-GAAP financial measure; and the substantive
reason
why management believes the non-GAAP financial measure provides
useful information to investors.

Note 2 - Summary of Significant Accounting Policies

Revenue Recognition, page F-9

3. We have read your response to our previous comment three and
request additional information regarding your accounting treatment
for commission revenue.  Specifically advise us why you believe
commission revenue should not be eliminated in consolidation in
situations where your wholly-owned subsidiary generates revenue
from
sales of your common stock.  Tell us the amount of commission
revenue
recognized from sales of Amreit stock in comparison to commission
revenue generated from broker-dealer transactions with your
unconsolidated affiliates.  Please advise us of the accounting
literature you relied upon.

      Please respond to the comments included in this letter
within
ten business days.  If you have any questions, you may contact
Thomas
Flinn, Staff Accountant, at (202) 551-3469 or the undersigned at
(202) 551-3413 if you have questions.
      			Sincerely,

      Cicely D. Luckey
Accounting Branch Chief

Chad C. Braun
Amreit
October 28, 2005
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