SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                   [LETTERHEAD THOMASVILLE BANCSHARES, INC.]

                                August 30, 2005

Ms. Michele Gohlke, Branch Chief
Division of Corporate Finance
Securities and Exchange Commission
Washington, DC 20549

Dear Ms. Gohlke:

      We are in receipt of your letter dated July 25, 2005.  On behalf of our
Management and our Board of Directors, we welcome and appreciate your comments
with respect to the Form 10-KSB filed by our Company, Thomasville Bancshares,
Inc. for the year ended December 31, 2004.  Your comments will strengthen our
compliance with applicable disclosure requirements, as well as enhance the
overall disclosures in our filings.

      Following are our responses to your comments, listed in the order
presented in your letter:

1.    Loans, Interest, and Fee Income on Loans, Page 8

      The accounting treatments governing commitment fees and costs under FASB
91 do not distinguish between commitment periods that are greater than or less
than one year; therefore, we will not make this distinction in the future.

      Our disclosure with respect to loan commitment fees covered FASB 91,
Section 49.  In future filings we will expand the disclosure to include FASB 91
Sections 8, 9 and 10, and to read as follows:  "Loan fees received for
commitments to originate or purchase a loan or a group of loans, net of certain
origination costs, are deferred and, if the commitment is exercised, recognized
over the life of the loan as an adjustment of yield or, if the commitment
expires unexercised, recognized as income upon the expiration of the
commitment."

2.    Trust and Money Management Assets and Income, Page 9

      In future filings, we will expand our revenue recognition policy to
clarify the point at which fee income from investment management services is
earned.  Such fees are earned on a straight line basis over the contractual
term of the arrangement or over the expected period during which the specific
management services are performed, whichever is longer.

3.    Goodwill and Other Intangibles, Page 11

      As stated in Note 18, one column represents the subsidiary bank while the
other column represents both the money management subsidiary (TNBFS) and the
parent company.  In future filings, and assuming no additions/reductions in
subsidiaries, we will include three columns; (i) Banking, including enhanced
product lines; (ii) TNBFS, money management services, and (iii) Other, which
will include the Parent Company.  Had we presented the segments based on the
above three-column format, TNBFS (the money management segment) would have
reported net income of $70,813 and $105,889 for 2004 and 2003, respectively.
The Parent Company's losses from operations (not including pass-through
dividends of $675,363 and $649,601 for 2004 and 2003, respectively) were
$284,385 and $231,750 for 2004 and 2003, respectively.

      No goodwill impairment charges were recorded in 2003 because TNBFS' income
for the year was slightly above expectation.  In 2004, however, income fell
below expectation, thus necessitating new assumptions with respect to future
profitability and cash flow.  These changes in future projections and
assumptions resulted in an impairment charge of $45,000 for the year ended
December 31, 2004.

4.    Recent Accounting Pronouncements, Page 12

      The Company did not have loans held-for-sale at any time during 2003 and
2004.  In future filings, if the Company engages in transactions involving loans
available-for-sale, we will disclose our accounting policies relative to those
loans.

      We acknowledge that (i) the Company is responsible for the adequacy and
accuracy of the disclosure in the filing; (ii) staff comments or changes to
disclosure in response to staff comments do not foreclose the Commission from
taking any action with respect to the filing; and (iii) 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.

      We trust that we have fully responded to your comments.  However, if
additional information or clarification are required, please do not hesitate to
contact me at (229) 226-3300.

                                        Sincerely,

                                        /s/Stephen H. Cheney
                                        Stephen H. Cheney, CEO
</TEXT>
</DOCUMENT>