SecProbe.io

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                          [JQH HOTELS, INC. LETTERHEAD]

                                  May 12, 2005

VIA EDGAR AND FACSIMILE
Ms. Linda Van Doorn
Senior Assistant Chief Accountant
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, DC  20549

         Re:  Form 10-K for the Year ended December 31, 2004
              JOHN Q. HAMMONS HOTELS, INC.
              File No. 1-13486
              JOHN Q. HAMMONS HOTELS, L.P. AND JOHN Q. HAMMONS HOTELS
              FINANCE CORPORATION III
              File No. 033-7334001

Dear Ms. Van Doorn:

         On behalf of John Q. Hammons Hotels, Inc., John Q. Hammons Hotels, L.P.
and John Q. Hammons Hotels Finance Corporation III (collectively, the
"Company"), I am writing to respond to the comments of the Staff (the "Staff")
of the Division of Corporation Finance of the Securities and Exchange Commission
(the "Commission") set forth in your letter dated April 22, 2005 with respect to
the above-referenced filings (the "Comment Letter").

         For ease of reference, each of the Staff's comments is reproduced below
in its entirety in bold and is followed by the corresponding response.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

MANAGEMENT DISCUSSION AND ANALYSIS

COMMENT 1:        PLEASE REFER TO THE FOURTH PARAGRAPH ON PAGE 24 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.

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Ms. Linda Van Doorn
April ____, 2005
Page 2

Response 1:       During 2001, the Company received engineering studies which
                  indicated that defective windows had allowed moisture to seep
                  into both the exterior skin of the building and the interior
                  walls in 16 hotels. The Company recognized that the net book
                  value of these assets was impaired. In 2001, the Company
                  recorded a charge to depreciation expense of $7.6 million to
                  reduce the net book value of these assets to zero.

                  During 2001-2004, the Company expended $12.6 million to
                  purchase replacement windows, replace the skin on the
                  buildings, and replace the interior walls. The Company has an
                  accounting policy on property, plant and equipment that
                  provides that expenditures for additions, betterments and
                  renewals are capitalized while maintenance and repair
                  expenditures, which do not extend productive life, are
                  expensed as incurred. In accordance with its policy, the
                  Company capitalized these expenditures as they were
                  betterments to the buildings

FINANCIAL STATEMENTS

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM, PAGE 47

COMMENT 2         PLEASE CONFIRM TO US THAT YOU HAVE A SIGNED AUDIT OPINION
                  THAT YOU WILL INCLUDE A CONFORMING SIGNATURE IN FUTURE
                  FILINGS. REFER TO SECTION 302 OF REGULATION S-T.

Response 2:       The Company does have a signed audit opinion for the
                  financial statements included in the Form 10-K for the year
                  ended December 31, 2004. A copy is enclosed with the faxed
                  copy of this letter for your information. We confirm that the
                  Company will include a conforming signature in all future
                  electronic filings.

NOTE 2 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

COMMENT 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.

Response 3:       The Company's consolidation policy (which has been included
                  in prior filings in the first sentence of Note 1, Entity
                  Matters) is that the consolidated financial statements include
                  the accounts of John Q. Hammons Hotels, Inc. , John Q. Hammons
                  Hotels L. P. and subsidiaries. The Company notes that it only
                  has wholly-owned subsidiaries. The

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Ms. Linda Van Doorn
April ____, 2005
Page 3

                  Company will also include this policy in Note 2, Summary of
                  Significant Accounting Policies, in future filings.

NOTE 6 COMMITMENTS AND CONTINGENCIES, PAGE 65

COMMENT 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 AMOUNTS 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.

Response 4:       The Company leases two trade centers from Mr. John Q.
                  Hammons ("Mr. Hammons") located in Joplin, Missouri and
                  Portland, Oregon. The Company believes that under both leases,
                  its financial statements reflect all of the expenses of
                  operating the center in accordance with SAB Topic 1B and that
                  the principal stockholder is not absorbing any costs which
                  should be reflected in the financial statements in accordance
                  with SAB Topic 5T.

                  Portland. The Company pays Mr. Hammons annual rent of
                  $300,000, and covers all operating expenses, for the trade
                  center in Portland, Oregon. That facility, immediately
                  adjacent to our hotel, is located near the airport. There is a
                  strong market for both convention and conference business in
                  Portland. The trade center, which collects fees for rentals
                  and any food and beverage provided, is profitable after rent
                  expense and operating costs, and also accounts for about 12%
                  of the occupancy of the attached hotel. The Company believes
                  the lease arrangement with Mr. Hammons is representative of
                  market rentals in the Portland area.

                  Joplin. In contrast, the Joplin trade center is not profitable
                  for the Company, despite the fact that rent is only $1 per
                  month.

                  The Holiday Inn -Joplin was built in 1979 (several years prior
                  to the formation of the Company). Mr. Hammons owned a piece of
                  irregularly shaped land near, but not contiguous to the hotel.
                  In 1992, thirteen years after opening the hotel, Mr. Hammons
                  built the trade center. The trade center is not attached to
                  the hotel but is over 100 yards away. Mr.

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Ms. Linda Van Doorn
April ____, 2005
Page 4

                  Hammons has advised the Company that at the time the trade
                  center was built, he believed that this was the best use for
                  this piece of land.

                  The Company signed a twenty year lease with Mr. Hammons in
                  1994 for the use of the trade center for rent of $1 per month.
                  Under the lease, the Company is responsible for all operating
                  costs as well as any capital expenditures and collects fees
                  for rentals and any food and beverage provided. The trade
                  center has never made a profit, and just breaks even despite
                  the minimal $1 rental payments after giving effect to the
                  operating costs. Further, related hotel traffic accounts for
                  less than 5% of the occupancy for the hotel.

                  Several factors contribute to the limited value of the Joplin
                  trade center. The Joplin market is much smaller than Portland,
                  and is not a strong convention or conference location, so
                  there is not a large market for a trade center-type facility.
                  In addition, the trade center is not easily accessible from
                  the nearest highway.

                  In conclusion, the Joplin trade center is not profitable and
                  the rent reasonably represents a market rate under these
                  circumstances. The Company's financial statements reflect all
                  the costs of operating the trade center under the lease.
                  Further, Mr. Hammons, the principal stockholder, is not
                  absorbing any of the costs of operating the trade center. The
                  business purpose for Mr. Hammons entering into the lease is
                  that he avoids bearing any costs of operating the facility for
                  a 20-year period, and can consider alternative uses for the
                  building at the end of the lease.

                                    * * * * *

         In accordance with the request in the Comment Letter, the Company
acknowledges that:

             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
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Ms. Linda Van Doorn
April ____, 2005
Page 5

             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.

         Please direct your questions or comments to me at 417-873-3537, or to
Mary Anne O'Connell at 314-480-1715.

                                         Very truly yours,

                                         /s/ Paul E. Mueller

                                         Paul E. Mueller, Executive Vice
                                         President and Chief Financial Officer

cc: Mr. Thomas Flinn
    Staff Accountant
    Mail Stop 0409
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