SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      April 22, 2005

Mail Stop 0409 via U.S. Mail and Fax (417) 873-3503

Mr. Paul E. Muellner
Chief Financial Officer
John Q. Hammons Hotels, Inc.
300 John Q. Hammons Parkway, Suite 900
Springfield, MO 65806

Re:	John Q. Hammons Hotels, L.P.
      John Q. Hammons Hotels Finance Corporation III
	Form10-K for the year ended December 31, 2004
      File No. 033-73340

Dear Mr. Muellner:

      We have reviewed your filing and have the following
comments.
We have limited our review to only the issues addressed below 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 document 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.

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

Managements Discussion and Analysis

1. Please refer to the fourth paragraph on page 25 and clarify to
us
how you accounted for the $12.6 million of costs incurred to
correct
the moisture problem.  Were the costs expensed in the periods
incurred?  If not, what was your basis for capitalizing the costs?
In addition, the note indicates that you recognized the cumulative
depreciation charge through December 31, 2004 of $7.6 million in
fiscal year 2001.  Please clarify to us in a supplemental response
the rationale and GAAP basis for this accounting treatment.

Financial Statements

Report of Independent  Registered Public Accounting Firm, page 42
2. Please confirm to us that you have a signed audit opinion and
that
you will include a conforming signature in future filings.  Refer
to
Section 302 of Regulation S-T.

Note 2 Summary of Significant Accounting Policies
3. Please provide us with your consolidation policy and undertake
to
include the policy in future filings.  Refer to Rule 3A-03 of
Regulation S-X.

Note 6 Commitments and Contingencies, page 59
4. The second paragraph under this heading indicates that the
Company
leases facilities from related parties at amounts that appear to
be
below fair value such as the lease for which only nominal amount
are
paid.  Please clarify to us what consideration you gave to
recording
the fair value of the lease payments as an expense with the
difference between the amounts paid and fair value recorded as a
capital contribution.  Refer to SAB Topic 1B and 5T.

      *    *    *    *

      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 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 Thomas Flinn, Staff Accountant, at (202)
824-
5225 or the undersigned at (202) 942-1964 if you have questions.

						Sincerely,

Linda Van Doorn
Senior Assistant Chief Accountant

John Q. Hammons Hotels, L.P.
April 22, 2005
Page 3

</TEXT>
</DOCUMENT>