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                      THE MAJOR AUTOMOTIVE COMPANIES, INC.
                            43-40 NORTHERN BOULEVARD
                           LONG ISLAND CITY, NY 11101

                                                                 August 22, 2005

VIA EDGAR TRANSMISSION
----------------------

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W
Mail Stop 3561
Washington, D.C. 20549

Re:      The Major Automotive Companies, Inc.
         Form 10-K for the year ended December 31, 2004
         Filed July 26, 2005
         File No. 000-29182

Ladies and Gentlemen:

         On behalf of The Major Automotive Companies, Inc. (the "Company"), set
forth below are the Company's responses to the Commission's comments given by
letter dated August 8, 2005 from Michael Moran, Branch Chief, Division of
Corporation Finance (the "Comment Letter"). The responses are numbered to
correspond to the comments set forth in the Comment Letter, which for
convenience, we have incorporated into the response letter.

Financial Statements
--------------------

Consolidated Statements of Operations, page F-5
-----------------------------------------------

1.       We note your revenues are derived from various sources including, but
         not limited to, automobiles, parts, fees, commissions and service.
         Please revise future filings to segregate sales of products from
         services on the face of the statements of operations. Also state
         separately the costs applicable to the related sales. Refer to Rule
         5-03 of Regulation S-X.

Response:

We believe that the Company's sources of revenue, other than vehicle sales, are
not material, either individually or in total. The aggregate of such revenues
have comprised approximately 10% of the Company's consolidated revenues in each
of the last two years. Accordingly, we do not believe that segregation of such
amounts and related costs on the face of the statement of operations will
provide significant benefit to readers of our financial statements.

Nevertheless, if the Staff believes that such disclosure is required, the
Company undertakes that future filings will be revised to segregate sales from
services on the face of the statements of

Securities and Exchange Commission
August 22, 2005
Page 2

operations and will separately present the related costs for each such category
of sales and service revenue. Please advise.

Consolidated Statements of Cash Flows, page F-9

2.        We note the changes in your floor plan notes payable are recorded as
          an operating activity on the statements of cash flows. Please tell us
          how classification as operating activities is consistent with
          paragraphs 21-24 of SFAS 95 and why financing activities
          classification is not more appropriate. Borrowings and repayments on
          floor plan notes payable for new and used vehicle inventory should be
          classified in financing activities when inventory is purchased from a
          manufacturer unaffiliated with the lender, similar to obtaining
          external financing through a line of credit or other borrowing
          facility. When the lender is affiliated with the manufacturer, those
          borrowing and repayments should be included in operating activities
          similar to accounts payable treatment. See paragraph 23a of SFAS 95.
          Also, note that Rule 5-02(19)(a) of Regulation S-X requires separate
          and clear balance sheet display of amounts payable to trade creditors
          and amounts payable for borrowings.

Response:

The Company has four floor plan financing sources, three of which are related to
automotive manufacturers (General Motors Acceptance Corporation ("GMAC"), Nissan
Motors Acceptance Corporation ("NMAC") and Primus, Inc. ("Primus")), and one of
which is a commercial bank, HSBC Bank USA ("HSBC"). Of the floor plan lenders
that are related to automobile manufacturers, two are related to manufacturers
of vehicles from which the Company purchases new vehicles and one is affiliated
with a manufacturer that has no relationship to the Company's new vehicle
purchases, as follows:

<TABLE>

      Dealership          Floor Plan Source               Vehicles Financed
      ----------          -----------------               -----------------

Major Chevrolet                  GMAC         New Chevrolets and all makes used vehicles
Major Chrysler Jeep Dodge        HSBC         New Chryslers and all makes used vehicles
Major Kia                        HSBC         New Kia and all makes used vehicles
Major Nissan                     NMAC         New Nissans and all makes used vehicles
Compass Dodge                   Primus        New Dodges and all makes used vehicles
</TABLE>

It is respectfully submitted that it is appropriate that the floor plan notes
payable changes be presented as a component of operating activities in the
statement of cash flows. We note this treatment is standard and consistent
throughout the industry. A review of the audited financial statements included
in the 2004 Form 10-K of each publicly held automobile dealership group, viz.,
United Auto Group, Inc., Lithia Motors, Inc., Group 1 Automotive, Inc., Sonic
Automotive, Inc. and Hometown Auto Retailers, Inc., indicates that each of our
competitors has classified the change in its floor plan liability in the same
manner as the Company, i.e. as an operating activity.

Securities and Exchange Commission
August 22, 2005
Page 3

Despite this result, if it remains the Staff's position that this reporting is
inconsistent with the intent of SFAS 95, the Company would undertake to comply
in its 2005 Form 10-K. Currently, the Company's accounting records are not
designed to easily capture the information necessary to historically report on
new vehicle inventory financed by a manufacturer-related source as
differentiated from used vehicle inventory financed by the same lender. Because
each of the dealerships sells both new and used vehicles and, as noted above,
the floor plan sources finance both new and used vehicles, some of which may be
obtained at closed auctions sponsored by the lender or manufacturer, it becomes
quite burdensome to go back and reconstruct the actual amounts attributable to
manufacturers unaffiliated with the lender from those that are affiliated. Among
other things, it requires determining the source of purchase for each vehicle in
the used vehicle inventory as well as the financing source at each period end.
The efforts required to gather this data retroactively would be, at the very
least, onerous.

Therefore, we propose beginning compliance starting with the 2005 Form 10-K. By
doing so, we can currently establish the systems to gather the information
necessary to produce accurate results for the current year. At the same time, we
can seek to gather the comparative data for the prior year. With two years of
data available, we can then make reasonable assumptions about the prior years,
for which all of the required information may no longer be available, and
present historical results, for the balance sheets, as well as the cash flows
statements that would be materially accurate.

Note 1. Nature of Business and Summary of Significant Accounting Policies, page
--------------------------------------------------------------------------------
F-11(k) Goodwill, page F-16
---------------------------

3.       Please describe the facts and circumstances leading to the goodwill
         impairment in 2004 as required by paragraph 47 of SFAS 142. In
         addition, expand your disclosure regarding the valuation method used to
         determine the amount of the impairment. Please show us what your
         disclosures will look like revised. Also expand your disclosure in
         MD&A.

Response:

As cited in Note 1 (k), the Company has been experiencing changes in its new and
used vehicle sales mix. In essence, there has been a shift to more new vehicles
sold combined with a decline in the growth rate of used vehicles. Since used
vehicles provide approximately twice the growth profit percentage of new
vehicles, this has negative implications in the Company's ability to increase
its profitability. When these changes in profitability are projected to future
periods, there appears to be a deterioration of the Company's cash flow.

An independent valuation expert, Empire Valuation Consultants, LLC ("Empire"),
utilizing a number of valuation methodologies, undertook a comprehensive
analysis of the Company to determine its fair value. Such methodologies included
the following:

Discounted cash flow
Guideline companies - total invested capital
Guideline companies - 5 year average EBITDA

Securities and Exchange Commission
August 22, 2005
Page 4

Guideline companies - 3 year average EBITDA
Guideline companies - trailing twelve months
EBITDA Market capitalization

After such evaluation, Empire concluded that the fair value of the Company was
less than its book value and, as a result, pursuant to the requirements of FAS
142, goodwill was impaired.

Empire then performed an appraisal pursuant to professional standards and
determined that the appropriate carrying value of the Company's goodwill as of
the Valuation Date was $5,135,989. Accordingly, the goodwill on the Company's
books was written down to this amount by means of an impairment charge of
$8,116,000 in the fourth quarter of 2004.

The valuation method used to determine the amount of the impairment will be
disclosed in future filings by revising the fourth sentence of the third
paragraph of Note 1 (k) (which now begins "Based on the results of the
tests...") to read:

         The valuation methods used to determine the amount of goodwill
         impairment included the discounted cash flows of future projected
         operating income, various extrapolations based on results and values of
         comparable companies and on a calculation of the Company's market
         capitalization. The results of these valuation methods indicated an
         impairment of goodwill, inasmuch as the recorded value of the Company's
         net assets (book value) was in excess of its calculated fair value.

Similar disclosure will be included in future disclosure under "Management's
Discussion & Analysis."

Note 2. Note Receivable Officer/Stockholder, page F-25
------------------------------------------------------

4.       Please tell us how you have evaluated the collectibility of the note
         receivable and what consideration was given to reflecting the
         receivable as a deduction from equity. Also advise us and revise your
         disclosure to describe the transaction that resulted in the note
         receivable. Refer to Staff Accounting Bulletin Topic 4:E and SFAS 57.

Response:

In connection with the note receivable officer/stockholder, all of which is due
from Mr. Bruce Bendell, collectibility has always been deemed to be reasonably
assured because amounts owed and/or committed to Mr. Bendell by the Company were
a substantial offset to (and often exceeded) such amounts. Mr. Bendell's
contractual $500,000 salary, his guaranteed $250,000 bonus and the amount of
$450,000 due him for credit enhancement, aggregate $1.2 million and could be
used to offset the note receivable from Mr. Bendell. At December 31, 2004, the
aggregate amount due to Mr. Bendell, $1,378,754, is approximately equal to the
amount of $1,395,358 that is due from Mr. Bendell.

Securities and Exchange Commission
August 22, 2005
Page 5

Additionally, Mr. Bendell has the means and the intent to repay this loan. As
such, we believe it would not be appropriate to reclassify this note receivable
as a deduction from equity.

We will expand our future disclosure of this note receivable by adding language
after the first sentence of Note 2., as follows:

         This note arose from a series of advances to the officer/stockholder.
         The Company has aggregate employment and related liabilities to this
         individual that substantially offset the amount due from him. It is,
         however, the Company's intent to obtain repayment of this note.

Note 8. Long-Term Debt, page F-31
---------------------------------

5.       Reference is made to the agreement with Doron Cohen and the potential
         forgiveness of Mr. Cohen's indebtedness in the amount of $1,048,067.
         Please clarify for us under what circumstances the debt would be
         forgiven and where you have recorded this note receivable in the
         balance sheet. Show us what your disclosures will look like revised.

Response:

The disclosure of Doron Cohen's separation agreement and debt forgiveness was
described in detail in the 2000 Form 10-K (Note 9, p. F-22). In that note it was
clear that his separation agreement covenants were independently valued and were
recorded on the books at a value less than his indebtedness to the Company. The
difference between the asset value and the receivable value was written off at
that time by a charge to a reserve. Part of the asset value was determined to
relate to the technology operations of the Company and that portion was written
off at that time to "Discontinued Operations." The portion remaining, i.e., the
value of the restrictive covenants relating to the automotive dealership
operations, was amortized over two years and was fully written off by the end of
2002. Therefore, the Company has no asset on its balance sheet for this
indebtedness from Doron Cohen and, in fact, at all times relevant only had a
"contingent asset," i.e., one that would only materialize if Mr. Cohen violated
his covenants. Since the five-year covenant period has now expired and there
have been no violations, there is no longer even a contingent asset.
Additionally, because the related liability to Mr. Cohen has been fully
satisfied during 2005, there will be no liability for this debt at year-end.

Accordingly, the only future disclosure regarding this transaction will be a
reference to the amounts due to Mr. Cohen at December 31, 2005 and 2004 and a
brief reference to the separation agreement that gave rise to this liability.
Such disclosure would be, as follows:

         Pursuant to a separation and release agreement dated August 8, 2000
         with its former president, the Company incurred a liability requiring
         periodic payments that aggregated $662,000. The $29,167 balance
         outstanding at December 31, 2004 was fully paid during 2005.

Securities and Exchange Commission
August 22, 2005
Page 6

Note 12. Commitments and Contingencies, page F-36
-------------------------------------------------

6.       We note you receive a bonus equal to 10% of net income, as defined.
         Please tell us how net income is defined and clarify how bonuses are
         earned in light of the net losses reported. Show us what your
         disclosures will look like revised including the amount of the bonus
         earned by you for each of the years presented.

Response:

The bonus is calculated based on the automotive dealership operations only.
Therefore, for bonus purposes, the "net income" is defined as the aggregate
pre-tax income for all of the individual dealerships. Accordingly, the Company
could have, and has experienced, profitable dealership operations and a
consolidated net loss. When there are substantial operating and/or other costs,
e.g., litigation, compliance or, as in 2004, an impairment of goodwill, if the
operations of the dealerships are profitable a bonus may be earned based on the
"net income" of the dealerships, even though the Company experienced a
consolidated net loss.

Future disclosure will be expanded by replacing the 4th sentence under
"Officer's Compensation" in Note 12 (which begins "Additional approval...") and
the balance of the paragraph, with the following:

         Ad