SecProbe.io

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								February 14, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail

Mr. Terrence J. Sheldon
Chief Executive Officer
T.J.T., Inc.
843 North Washington, P.O. Box 278
Emmett, Idaho 83617

RE:	T.J.T., Inc. (the "Company")
	Form 10-K for the year ended September 30, 2004
	File No. 0-27340

Dear Mr. Sheldon:

We have reviewed your filing and have the following comments.
Where
indicated, we think you should revise your future filings 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.

Please respond to confirm that such comments will be complied
with,
or, if certain of the comments are deemed inappropriate by the
Company, advise the staff of the reason thereof.

Pursuant to Rule 101(a)(3) of Regulation S-T, your response should
be
also be submitted in electronic form, under the label "corresp"
with
a copy to the staff.  Please respond within fifteen (15) business
days.

Form 10-K for the Fiscal year-ended September 30, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Results of Operations, page 9

1. As discussed in our recent Interpretive Release about
Management`s
Discussion and Analysis (FR-72), one of the primary objectives in
preparing this section should be to provide a narrative
explanation
of the financial statements that enables investors to see the
company
through the eyes of management.  As such, please expand upon your
disclosures in future filings to provide further analysis of the
changes in operating results year-over-year.  Please expand your
disclosures to include information, such as, but not limited to:
* Significant drivers of the 15% increase in sales by your
accessories and siding segment.
* The reason the manufactured housing industry experienced an
increase in shipments, but your results do not reflect a similar
increase.
* The effect that entering the agricultural market through the
sales
of metal buildings has had and is expected to have on your
operating
results.
* More detailed information with regard to the components of your
selling, general and administrative expenses and the changes in
such
expenses from period to period.

Item 8.  Financial Statements and Supplementary Data

Statements of Operation, page 16

2. Please revise to segregate Operating Expenses from SG&A in
accordance with Rule 5-03(b)(3) and (4) of Regulation S-X, or
explain
why you do not believe this is required.

3. We note that you recorded a gain on the sale of assets of
$21,000
in the current year.  It appears that you have currently presented
this gain in the non-operating activities portion of your
Statement
of Operations.  In accordance with paragraph 45 of SFAS No. 144, a
gain or loss recognized on the sale of a long-lived asset shall be
included in "income from operations," if such a subtotal is
presented
in the statement of operations.  In future filings, please
reclassify
your gains and losses recognized on the sale of long-lived assets
as
a component of operating income for all years presented.  The
gains/(losses) on the disposition of investment property should be
similarly reclassified.

4. We note that you sold a portion of your land held for
investment
in the current year.  Based upon your disclosure in "Note A -
Significant Accounting Policies," it appears that you recognize
the
sale of land held for investment as an installment sale, when your
company provides virtually 100 percent financing to the buyer.  As
such, please tell us whether any of the land sold during the
periods
presented in your financial statements was recorded as an
installment
sale, as a result of financing provided to the buyer.  If so,
please
expand your disclosures in future filings relating to your real
estate sales to comply with the requirements of paragraph 59 of
SFAS
No. 66, which requires that the income statement, or related
footnotes, for the period including the date of sale should
present
the sales value, the gross profit that has not yet been
recognized,
and the total cost of the sale.

Notes to Financial Statements

Note A - Significant Accounting Policies

Earnings per Share, page 21

5. We note that you state that "130,000, 123,000, and 88,000 of
the
total options outstanding at September 30, 2004, 2003, and 2002,
respectively, were not included in the diluted earnings per share
calculation because the exercise price of the options were greater
than the average market price of common shares."  As 220,000;
230,000; and 160,000 options were outstanding at the end of fiscal
years 2004, 2003, and 2002, respectively, it appears that there
were
options which were included in the weighted average shares used in
your dilutive EPS calculation.  Paragraph 40(a) of SFAS No. 128
indicates that you should provide a reconciliation of the
numerators
and the denominators of the basic and diluted per-share
computations
for income from continuing operations, for each period that you
have
presented an income statement.  Please expand upon your disclosure
in
future filings to include these disclosures.  Illustration 2 of
Appendix C to SFAS No. 128 provides an example of this
presentation.
Also, revise your future filings to disclose your "basic" and
"diluted" earnings per common share on your consolidated
statements
of operations.  Refer to the requirements of paragraph 36 of SFAS
No.
128.

Note B - Inventories

6. Revise the notes to your financial statements and your
discussion
of "Critical Accounting Policies" in future filings to clarify the
nature of the inventories that are valued using the first-in,
first-
out and average-cost inventory methods.

Note F - Credit Facility, page 26

7. We note per "Item 5." of your Form 10-K, that your revolving
line
of credit prohibits the company from paying dividends.  Rule 4-
08(e)
of Regulation S-X indicates that restrictions which limit the
payment
of dividends by the registrant should be disclosed in the
financial
statement footnotes.  Please disclose the restrictions that
prevent
the payment of dividends by your company in the financial
statement
footnotes in future filings.

Note K - Related party Transactions, page 29

8. We note per the financial statements which you filed for your
significant equity investee - NewCo Tire and Axle L.L.C  ("NewCo")
-
that you sold approximately $118,000 in tires and axles to this
company.  As your filing only discloses the income recognized from
equipment rentals to your equity investee, please expand upon the
related party footnote in your future filings to include all
transactions between your company and NewCo.  Refer to the
requirements of paragraph 2 of SFAS No. 57.

Note M - Business Segments, page 30

9. You state that your identifiable assets are assigned to
operating
locations rather than operating segments, with depreciation
allocated
to the segments based upon usage.  As paragraph 27 of SFAS No. 131
indicates that an enterprise shall report a measure of total
assets
for each reportable segment, please revise future filings to
disclose
the total assets for each of your segments or explain in further
detail why you are unable to do so.  In this regard, we do not
understand how you can determine the amount of capital
expenditures
for each segment, but not its total assets.  Please advise or
revise
as appropriate.

Form 10-K/A for the year-ended September 30, 2004

Item 15.  Exhibits, Statement Schedules and Reports on Form 8-K

10. We note that you filed separate financial statements of NewCo
as
an Exhibit in Item 15 of your 10-K/A filed on January 31, 2005, in
order to comply with the requirements of Rule 3-09 of Regulation
S-X.
Rule 3-09(b) of Regulation S-X requires that the financial
statements
be filed for the same periods required by Rules 3-01 and 3-02 of
Regulation S-X.  As you have filed in your Form 10-K/A, only the
financial statements of your significant equity investee, for its
latest fiscal year-end, please amend your filing to include
financial
statements for its prior fiscal year.  Also, it appears that the
additional financial statements required for the prior fiscal year
should be audited, since your equity in the earnings of this
entity
exceeded the 20% significance threshold in that year, also.

Other

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.  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 in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; 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 filing or in response to
our comments on your filing.

You may contact Jeffrey Sears at (202) 824-5646 if you have
questions
regarding comments on the financial statements and related
matters.
Please contact the undersigned at (202) 942-1936 with any other
questions.

								Sincerely,

								Linda Cvrkel
								Branch Chief

Via facsimile:  Larry B. Prescott, CFO
		(208) 365-3983
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Mr. Terrence J. Sheldon
T.J.T., Inc.
February 14, 2005
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