SecProbe.io

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                   JOHN Q. HAMMONS HOTELS & RESORTS LETTERHEAD

                                  June 23, 2005

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:      JOHN Q. HAMMONS HOTELS, INC.
                  Form 10-K for the Year ended December 31, 2004
                  File No. 1-13486
                  JOHN Q. HAMMONS HOTELS, LP
                  Form 10-K for the year ended December 31, 2004
                  File No. 033-73340

Dear Ms. Van Doorn:

         On behalf of John Q. Hammons Hotels, Inc. (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 May 19, 2005 with respect to the above-referenced
filing (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

FINANCIAL STATEMENTS

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM, PAGE 47
COMMENT 1     WE NOTE IN YOUR RESPONSE TO OUR PREVIOUS COMMENT 2 THAT THE
              COMPANY FAXED A COPY OF THE SIGNED AUDIT OPINION WITH YOUR
              RESPONSE. IT IS NOTED THAT WE DID NOT RECEIVE A COPY OF THE
              OPINION IN YOUR PREVIOUS FAX AND AT THIS TIME WE DO NOT NEED A
              COPY OF THE AUDIT OPINION, AS WE ARE RELYING ON YOUR
              REPRESENTATION THAT YOU OBTAINED A SIGNED COPY AS REQUIRED BY
              REGULATION S-T.

Response 1:   The Staff's comments are noted.

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Ms. Linda Van Doorn
June 23, 2005
Page 2

NOTE 6 COMMITMENTS AND CONTINGENCIES, PAGE 65

COMMENT 2:    WE HAVE CONSIDERED YOUR RESPONSE TO OUR PREVIOUS COMMENT 4 AND
              NOTE THAT WHETHER THE BUSINESSES ARE OPERATING AT A LOSS OR
              WHETHER THE BUSINESS HAS AN OPERATING PROFIT AFTER MAKING RENTAL
              PAYMENTS ARE SEPARATE QUESTIONS FROM WHETHER THE RENTAL PAYMENTS
              ARE THE EQUIVALENT OF FAIR MARKET LEASE RATES IF THE LESSOR WERE
              AN INDEPENDENT THIRD PARTY. PLEASE ADDRESS THE LATTER QUESTION IN
              YOUR NEXT RESPONSE.

Response 2:   In order to determine whether the rental payments are the
              equivalent of fair market lease rates in response to your comment,
              the Company retained a national, independent valuation firm to
              identify the current market rental for medium size convention
              center space in the Joplin, Missouri area that would be applicable
              to the property known as the John Q. Hammons Convention Center.
              The valuation firm estimated the annual lease rate, on a triple
              net basis, to be approximately $86,000.

              Since the Company was recording $12 of lease expense for this
              property, the difference that should have been recorded is
              approximately $86,000 of annual lease expense. The Company does
              not believe that these amounts are material to any prior periods.
              In reaching this conclusion, the Company considered whether these
              amounts were material quantitatively or qualitatively under the
              guidance of SAB 99. Quantitatively, the amounts were not material
              to any of the last three fiscal years or interim periods. None of
              the three most recent annual or their interim periods would be
              impacted by more than 3.1% of income from continuing operations by
              recording this additional lease expense. None of the qualitative
              characteristics in SAB 99 were met. Therefore, the Company does
              not believe that restatement of prior periods financial statements
              is necessary. However, the Company will correct its accounting in
              second quarter 2005 financial statements to record the cumulative
              effect of rental expense at fair market rental rates which is
              immaterial to expected 2005 income from operations.

                                    * * * * *

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

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Ms. Linda Van Doorn
June 23, 2005
Page 3

              -    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.

         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. Muellner

                                                 Paul E. Muellner
cc:   Mr. Thomas Flinn
      Staff Accountant
      Mail Stop 0409

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