SecProbe.io

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Mail Stop 0308

      May 26, 2005

Mr. E. Lee Wyatt, Jr.
Executive Vice President, Chief Financial Officer
and Treasurer
Sonic Automotive, Inc.
6415 Idlewood Road
Charlotte, NC 28212

	RE:	Sonic Automotive, Inc.
      Form 10-K for the Year Ended December 31, 2004
      Form 10-Q for the Quarter Ended March 31, 2005
      File No. 1-13395

Dear Mr. Wyatt:

		We have reviewed your response filed on May 13, 2005 to
our
comment letter dated April 5, 2005 and have the following
additional
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 information so we may
better understand your disclosure.  After reviewing this
information,
we may 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.

Form 10-K for the Year Ended December 31, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations
Results of Operations, page 19

1. We note your response to comment number 3 in our letter dated
April 5, 2005 and the disclosure in your quarterly report filed on
May 6, 2005.  Please tell us and disclose in future filings the
type
of expenses classified in cost of sales and capitalized in
inventories.  In your future annual and quarterly filings, please
quantify and provide an analysis of material changes in cost of
products and expenses included in cost of sales.

Notes to Consolidated Financial Statements
Note 1.  Description of Business and Summary of Significant
Accounting Policies
Advertising, page F-12

2. We note your response to comment number 13 in our letter dated
April 5, 2005 relating to your plans not to disclose of the amount
of
cooperative advertising reimbursements netted against gross
advertising expense.  We believe disclosure of the amount of
cooperative advertising credits netted against advertising expense
is
necessary to meet the requirements of paragraph 49(c) of SOP 93-7.
In future filings, please revise your disclosure accordingly.
Please
also disclose:
* the number of vendors with whom you have reimbursement
agreements;
* the terms and conditions of the vendor agreements;
* whether or not you would continue to incur the same level of
advertising expenditures if vendors discontinued their
reimbursements
of cooperative advertising expenses, and in Management`s
Discussion
and Analysis of Financial Condition and Results of Operations
discuss
the impact that vendor allowances have on your results of
operations
in terms of generating additional revenues; and
* the dollar amount of excess reimbursements over costs incurred
that
are recorded as a reduction of cost of sales.

Form 10-Q for the Quarter Ended March 31, 2005

Part II - Other Information
Item 6:  Exhibits

3. In future filings please include all of the exhibits required
by
Item 601 of Regulation S-K in the exhibit index.  Previously filed
documents may be incorporated by reference to satisfy the filing
requirements.

	Please respond to these comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
response letter that keys your responses to our comments and
provides
any requested information.  Please file your response letter on
EDGAR
as a correspondence file.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your responses to our comments.

You may contact Bill Thompson, Staff Accountant, at (202) 551-3344
or
Donna Di Silvio, Staff Accountant, at (202) 551-3202, or in their
absence, the undersigned at (202) 551-3841 if you have any
questions
regarding these comments.

      Sincerely,

								Mike Moran
								Accounting Branch Chief

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Mr. E. Lee Wyatt, Jr.
Sonic Automotive, Inc.
May 26, 2005
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