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                      THE MAJOR AUTOMOTIVE COMPANIES, INC.
                            43-40 Northern Boulevard
                           Long Island city, NY 11101

                                                                October 14, 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 September 28, 2005 from Michael Moran, Branch Chief, Division of
Corporate 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.       Please clarify your response to comment 1 in our letter dated August 8,
         2005. If you are stating that you have combined the revenues derived
         from various sources because each class is less than 10 percent of the
         sum of the items such that you have complied with Rule 5-03 of
         Regulation S-X no revision is necessary. Otherwise please revise to
         segregate sales of products from services on the face of the statements
         of operations and state separately the costs applicable to the related
         sales in accordance with Rule 5-03 of Regulation S-X.

Response:

Each class of the Company's sources of revenue is less than 10 percent of the
aggregate of all such items. Accordingly, no revised disclosure is required.

Securities and Exchange Commission
October 14, 2005
Page 2

Consolidated Statements of Cash Flows, page F-9
-----------------------------------------------

2.       We note your response to comment 2 in our letter dated August 8, 2005.
         Please address the following items:

o        Advise us how inventory purchased from a commercial bank or
         manufacturer unaffiliated with the lender represents an operating
         activity as set forth in paragraphs 21-24 of SFAS 95 or revise
         accordingly. Please note that under paragraph 23a of SFAS 95, payments
         to suppliers to acquire goods for resale should be classified as
         operating activities. Therefore, borrowings and payments on floor plan
         notes payable for new and used 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. Refer to AICPA
         TIS Section 1300.16 for further guidance.

Response:

We will revise our financial statements to classify payments on floor plan notes
payable for new and used inventory in financing activities when inventory is
purchased from a manufacturer unaffiliated with the lender and in operating
activities when the financed inventory is purchased from a lender that is
affiliated with the manufacturer.

o        You state it would be burdensome to reconstruct actual amounts
         attributable to manufacturers unaffiliated with the lender and to
         distinguish between new and used vehicle financing obtained from the
         same source. We understand that GMAC, for example, directly pays the
         manufacturer from which you purchase your new vehicle inventory and
         that you do not have the discretion to receive these funds prior to
         disbursement to the manufacturer. We also assume that a minimal amount
         of your used vehicle inventories are obtained from your manufacturers
         and that you receive access to the cash for used vehicle financing
         prior to disbursement. As such, please advise us of the approximate
         amount of related borrowings and repayments used in the purchase of
         used vehicle inventory. Also, tell us the total amount amounts related
         to the commercial bank, HSBC USA and Primus. Please confirm that these
         assumptions are correct or advise us of the cash flows associated with
         the financing of your inventory.

Response:

We are gathering the data that has been requested and expect to have it
completed and filed with the Commission by October 21, 2005.

Securities and Exchange Commission
October 14, 2005
Page 3

o        As previously stated, Rule 5-02(19)(a) of Regulation S-X requires
         separate and clear display of amounts payable to trade creditors and
         amounts payable for borrowings. Please revise your balance sheet to
         distinguish between floor plan notes payable to trade creditors and
         floor plan notes payable that are non-trade.

Response:

We will revise our balance sheet to distinguish between floor plan notes payable
to trade creditors and floor plan notes that are non-trade.

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

3.       As previously requested, advise us and revise your disclosure to
         describe each transaction that resulted in the note receivable. Tell us
         if any of the advances were used to purchase stock. Refer to Staff
         Accounting Bulletin Topic 4:E and SFAS 57.

Response:

All amounts included in the note receivable reflect a number of cash advances of
varying amounts at various times that were made to Mr. Bruce Bendell prior to
2003. There has been no change in the balance since 2002. None of these advances
was used for the purchase of the Company's stock. Therefore, since there was
neither any effect on the balance sheet or income statement in any of the
periods presented nor is there any amount receivable for the purchase of the
Company's stock, we do not believe that additional disclosure of this fact is
required or provides benefit to a reader of the Company's financial statements.
Nevertheless, we will retroactively revise our disclosure to that which was
noted in our response dated August 22, 2005 to the previous comment letter.

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

4.       We note your response to comment 6 in our letter dated August 8, 2005.
         Please expand to provide transparent disclosure of the amount of net
         income, as defined, that is used in calculating the bonus for each year
         presented. We note the impairment of goodwill in 2004 however it is not
         evident how a bonus was based on the aggregate pre-tax income of the
         dealerships after all expenses in 2003 when there is a loss before
         taxes.

Securities and Exchange Commission
October 14, 2005
Page 4

Response:

As previously indicated, the bonus is calculated based on the "net income" of
the automotive dealership operations, only. There are substantial corporate
costs of, inter alia, being a public company (approximately $1.2 million,
annually) and settlements of litigation related to our former non-automotive
technology operations (approximately $500,000 in 2003), as well as miscellaneous
operating expenses incurred in the Company's leasing operations, all of which
are not directly related to dealership operations, that therefore are not
included in the calculation of the dealerships' "net income." Although in both
2003 and 2004 the dealerships were profitable, the Company had a pre-tax loss on
a consolidated basis. In 2003, the dealerships "net income" upon which the bonus
was based was $775,336, while the Company had a consolidated pre-tax loss of
$1,048,346. Therefore, the bonus was $77,533. The bonus was approved by the
Company's Board of Directors. We will retroactively revise our disclosure to
that which was noted in our response dated August 22, 2005 to the previous
comment letter and include the "net income" amounts from which such bonus
amounts were calculated.

The Company hereby acknowledges that (i) it 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 note that simultaneously with the filing of this response letter, the Company
is filing a preliminary proxy statement and a Schedule 13E-3 in connection with
a proposed deregistration under Section 12(g) of the Securities Exchange Act of
1934, as amended. The Company hereby acknowledges and undertakes that it will
not distribute definitive proxy materials to its stockholders until such time as
it fully addresses all of the Commission's concerns as outlined in the
Commission's letters of August 8, 2005 and September 28, 2005 and to the extent
required, amends any prior periodic filing reports filed with the Commission as
requested thereby.

Securities and Exchange Commission
October 14, 2005
Page 5

Please call the undersigned at (718) 937-3700 with any comments or questions
regarding the Company's response and please send a copy of any written comments
to the following parties:

                                MITCHELL LITTMAN, ESQ.
                                MARK F. COLDWELL, ESQ.
                                  Littman Krooks LLP
                                   655 Third Avenue
                                  New York, NY 10017
                                Phone: (212) 490-2020
                                 Fax: (212) 490-2990

                                         Very truly yours,

                                         /s/ Bruce Bendell

                                         Bruce Bendell, Chief Executive Officer

cc:      Securities and Exchange Commission
         ----------------------------------

         Donna Di Silvio, Esq.

         The Major Automotive Companies, Inc.
         ------------------------------------

         Alan Pearson
         Eric Keltz, Esq.
         Richard L. Feinstein

         Littman Krooks LLP
         ------------------

         Mitchell Littman, Esq.

         BDO Seidman
         -----------
         Adam Roth