SecProbe.io

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                        [MAJESTIC STAR CASINO LETTERHEAD]

May 27, 2005

VIA EDGAR AND FACSIMILE

Mr. Joseph Foti
Senior Assistant Chief Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

RE:      THE MAJESTIC STAR CASINO, LLC
         FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004
         COMMISSION FILE NO. 333-06489

Dear Mr. Foti:

On behalf of The Majestic Star Casino, LLC (the "Company"), we are responding to
the Staff's comment letter dated April 27, 2005, with respect to our Form 10-K
for the year ended December 31, 2004. This is to confirm your agreement that a
response to the April 27th comment letter by May 31, 2005 would be deemed
timely.

We have set forth below in italics each question contained in the April 27th
comment letter, followed by our response thereto.

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

Contractual Commitments, page 39

1.   We note from note 6 to the financial statements that you are required to
     pay the City of Gary, Indiana a 3% economic incentive in accordance with a
     development agreement entered into in 1996. In future filings, please
     include this obligation in the section of Contractual Commitments in MD&A
     by accruing your best estimate in the table and explaining your assumptions
     in a note, or by discussing the pertinent details of the obligation in the
     Contractual Commitments section of MD&A. See Item 303(a)(5) of Regulation
     S-K.

     RESPONSE: In future filings, we will discuss the pertinent details of our
     development agreement with the City of Gary, Indiana within the Contractual
     Commitments section of MD&A.

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Mr. Joseph Foti
May 27, 2005
Page 2

Financial Statements

Consolidated Statements of Operations, page F-4

2.   We note your presentation of equity in loss of joint venture as part of
     operating income. Please review future filings to present the equity in
     this investment as a line item below operating income. See Rule 5-03(b)(13)
     of Regulation S-X.

     RESPONSE: The Company's Indiana riverboat operation ("Majestic Star")
     operates from the Buffington Harbor gaming complex, which we share with a
     Trump riverboat casino (the "Trump Casino"). The Company owns 50% of the
     equity interests of Buffington Harbor Riverboats, LLC ("BHR"), a joint
     venture with Trump Indiana, Inc. ("Trump Indiana"). BHR owns a two-level
     facility that provides a centralized location from which customers can
     board either Majestic Star or the Trump Casino. BHR also contains
     restaurants, gift shops, a VIP lounge and other amenities. BHR has no
     significant operating assets or liabilities other than the boarding
     facility and related amenities. Approximately 96% of BHR's assets are
     property and equipment and there is no third-party debt other than a
     capital lease in the amount of $388,492.

     The Company and Trump Indiana have each entered an agreement with BHR to
     use BHR for their respective gaming operations, and have committed to
     reimburse BHR for its cash operating losses, and fund BHR's capital
     expenditures and debt obligations. The Company and Trump Indiana share
     equally in the operating expenses relating to the BHR property, except for
     costs associated with those food and beverage operations not operated by
     third parties, and valet operations, which are allocated on a percentage of
     use by the casino customers of Majestic Star and Trump Casino. Accordingly,
     BHR has no independent operations and, after reimbursement of cash
     operating expenses each year, its only remaining operating loss is
     comprised of depreciation.

     Rule 5-03 of Regulation S-X indicates that the equity in earnings of a
     joint venture should be shown after the computation of operating income,
     and before net income in the presentation of the income statement. However,
     the rule indicates that "if justified by the circumstances, this item may
     be presented in a different position". We believe it appropriate to reflect
     the loss as a component of operating income, given the nature of the joint
     venture as an operational cost sharing arrangement, and the fact that the
     Company's share of BHR's losses is solely comprised of depreciation.

Notes to Financial Statements

Note 1. Organization, page F-8

3.   We note from the Form 8-K filed December 31, 2003, that in connection with
     the spin-off of Barden Nevada, you entered into (1) a license agreement to
     allow the purchaser the right to use the name "Fitzgeralds", (2) a
     management services agreement, and (3) a one-year credit
<PAGE>
Mr. Joseph Foti
May 27, 2005
Page 3

     agreement. In this regard, supplementally tell us how you determined that
     you did not have significant continuing involvement in Barden Nevada
     supporting your discontinued operations accounting treatment. See paragraph
     42 of SFAS 144 and EITF 03-13. We may have further comments.

     RESPONSE: Paragraph 42 of SFAS 144 indicates that the "results of
     operations of a component of an entity that...has been disposed of...shall
     be reported in discontinued operations...if both of the following
     conditions are met: (a) the operations and cash flows of the component have
     been...eliminated from the ongoing operations of the entity as a result of
     the disposal transaction and (b) the entity will not have any significant
     continuing involvement in the operations of the component after the
     disposal transaction."

     With regard to item (b), the Staff has identified certain matters as
     potential indicators that the Company has a significant continuing
     involvement with Barden Nevada Gaming, LLC ("Barden Nevada") following its
     spin off on December 31, 2003. We evaluated each of these matters in
     connection with our initial determination of whether to report Barden
     Nevada as a discontinued operation in our financial statements. That
     evaluation took into account the provisions of Issue 2 of EITF 03-13,
     "Applying the Conditions in Paragraph 42 of FASB Statement No. 144 in
     Determining Whether to Report Discontinued Operations". Both quantitative
     and qualitative factors regarding the Company's contractual arrangements
     with Barden Nevada were considered, as required by paragraph 10 of that
     EITF, and we specifically addressed the factors identified in paragraph 11
     of that EITF. The results of our evaluation were as follows:

     -    The Company does not maintain an ownership interest or any voting
          control with respect to Barden Nevada.

     -    With respect to arrangements that could result in an indirect means of
          affecting Barden Nevada's operating or financial policies, we did
          consider the fact that the Company has entered into an arrangement
          with Barden Nevada to provide certain support and administration
          functions on a cost-reimbursement basis. These functions include: (i)
          certain human resources related services including coordination of
          benefits and benefit administration, wage rate evaluation for
          employees, legal review of claims and development of proposed policies
          and procedures (but not decision making relating to such actions);
          (ii) legal and internal audit oversight services (to meet minimum
          required internal controls mandated by the Nevada gaming authorities):
          (iii) risk management and information technology assistance; (iv)
          marketing and advertising services which Barden Nevada engages the
          Company to perform; and (v) and certain services related to facilities
          expansion and design..

     -    Although the Form 8-K filed December 31, 2003 referenced a management
          services agreement, the agreement is entitled "Expense Sharing
          Agreement," which, as described above, more accurately describes the
          substance of such agreement. In particular, the

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Mr. Joseph Foti
May 27, 2005
Page 4

          Company is not engaged in management decision making at Barden Nevada.
          The Company's role in these matters is not, in our judgment,
          "sufficient to enable the ongoing entity to exert significant
          influence over the disposed component's operating and financial
          policies", as outlined in the EITF. Such operating and financial
          management is carried out by Barden Nevada's General Manager and
          Controller, which individuals are not employees of the Company, and
          report directly to Barden Nevada's owner and not the Company's
          management.

     -    Finally, we also considered that the cost of these services - at
          approximately $1.1 million in 2004 - represented approximately 2.0% of
          Barden Nevada's overall operating expenses of $51.8 million. We do not
          consider this to indicate a "significance of the contract or
          arrangement to the overall operations of the disposed component,"
          which is a factor to be considered in applying the EITF.

     With respect to the licensing of the "Fitzgerald's" name, we point out that
     such license was essentially distributed to Barden Nevada as part of the
     spin-off, because of the fact that the license is granted in perpetuity and
     the Company receives no royalty or other continuing cash flows from Barden
     Nevada for such license. Accordingly, we do not believe that this matter
     impacts our ability to account for Barden Nevada as a discontinued
     operation.

     Finally, as noted by the Staff, on January 1, 2004, we extended a
     short-term line of credit to Barden Nevada, which was not drawn upon prior
     to its termination on December 31, 2004. The reason for the short-term line
     of credit was to provide liquidity if necessary. The $1.0 line of credit
     line of credit represented less than 3.0% of Barden Nevada's capitalization
     when issued.

     Please note that our outside lending arrangements permitted the Company to
     make up to $5.0 million available to Barden Nevada. Barden Nevada generates
     positive cash flows from operations and it was not considered essential to
     its ability to continue as a going concern. In March 2005, a new line of
     credit was provided to Barden Nevada in the amount of $5.0 million, of
     which $3.6 million was drawn at March 31, 2005. The line of credit matures
     on October 7, 2007, and the Company charges interest on the borrowings at a
     rate equivalent to the borrowing rate under the Company's credit facility.
     This new line of credit does not change our analysis regarding accounting
     for Barden Nevada as a discontinued operation.

     A qualitative factor that needs to be considered regarding our presentation
     of Barden Nevada as a discontinued operation has to do with financial
     information that is now pertinent with the Company's bondholders and
     analysts. On October 7, 2003, the Company refinanced substantially all of
     its outstanding debt. On that date, Barden Nevada became an unrestricted
     subsidiary of the Company and a non-guarantor of the new debt issued by the
     Company as a result of the refinancing transactions. The Company files
     reports with the SEC pursuant to the contractual obligations in its
     indenture governing its 9 1/2% Senior Secured Notes. Since Barden Nevada is
     not a guarantor of the notes, the financial position, operating activities
     and cash flows of Barden Nevada are not relevant to the Company's
     bondholders. We believe

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Mr. Joseph Foti
May 27, 2005
Page 5

     that to reflect Barden Nevada as anything but a discontinued operation
     would create confusion over the Company's pertinent financial results.

     For the above reasons, we believe that presentation of Barden Nevada as a
     discontinued operation is appropriate.

Note 3. Basis of Presentation

Concentration of Credit Risk, page F-10

4.   We note your disclosure that you have established an allowance for doubtful
     accounts related to your accounts receivables, which approximates fair
     value. Please supplementally tell us, and disclose in future filings, a
     description of the accounting policies and methodology used to estimate the
     allowance for doubtful accounts, the policy for charging off uncollectible
     loans and trade receivables, and the policy for determining past due or
     delinquency status. See paragraph 13a-c of SOP 01-6.

     RESPONSE: The primary source of our accounts receivables is from the
     extension of credit, in the form of markers (which are basically draft
     instruments), to our casino customers and the cashing of checks (personal,
     payroll, travelers, etc). The extension of credit or cashing of checks is
     granted after the evaluation of the customer's credit worthiness. The
     evaluation could result in the granting of immediate credit (limited to
     certain amounts) with appropriate identification, or higher amounts of
     credit after obtaining a credit history from an information service bureau.
     We also have receivables that are created from commissions due from certain
     third parties for whom we perform services (ATMs and credit and debit card
     cash advance services), leases of retail space in our casinos to third
     parties, amounts due on hotel rooms and ancillary hotel related charges,
     and credit card charges that have not been submitted for processing or are
     currently in processing, but for which our bank account has not been
     credited with the funds.

     A receivable is recognized at the time the credit is provided or the
     service is performed for our customers (or at the time the bank notifies us
     that draft instrument is going to be returned), or in the event of
     commissions and leases, when earned.

     An account is considered past due or delinquent when payment is not
     received timely or a draft is returned from the bank. We look at
     individually large accounts for specific determination of collection. In
     addition, we look at the aging of those receivables that are not
     individually large enough to warrant a specific review, to establish the
     allowance for doubtful accounts. Our property management teams will
     generally establish greater allowances as a percentage of the total
     balance, based on the age of the receivable, and which percentage is based
     on our historical experience. We also establish an initial allowance on all
     returned items based on our historical collection experience. In addition,
     unless we have specific payment arrangements with a customer, we will not
     carry any receivable at less than 100% allowance after it is 120 days
     past-due, as our experience shows that the collection is

<PAGE>
Mr. Joseph Foti
May 27, 2005
Page 6

     remote. Of course, those receivables that we know will not be collected
     (fraud, bankruptcy, etc.) are fully provided for when we obtain an
     indication that they will not be collectable. We have not experienced any
     fiscal quarters in which provisions for, or recoveries on, our receivables
     have been material to our financial statements.

     Our properties use credit committees to evaluate receivables, implement
     collection methods, establish the allowance for doubtful accounts, and
     recommend accounts be written off. Credit committees are made up of senior
     management at our casino properties, and meet on a regular basis. Accounts
     are generally written off when all methods of collection that we can