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BrasilTelecom

                                                 December 07, 2005

Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
Washington, DC 20549 (USA)

     Re:  Brasil Telecom Participacoes S.A. (the "Company")
          Form 20-F for Fiscal Year Ended December 31, 2004
          Filed June 15, 2005
          File No. 1-14477

Dear Mr. Spirgel:

     Brasil Telecom Participacoes S.A. ("BrTP") is structured as a holding
company, and conducts substantially all of its operations through its only and
wholly owned subsidiary Brasil Telecom S.A. ("BrT"). Following are our responses
to the comment letter dated November 22, 2005, regarding the report referred to
above:

     Item 15. Controls and Procedures, page 137
     ------------------------------------------

     1.   We note that your principal executive officer and principal financial
          officer concluded that your disclosure controls and procedures were
          "effective in recording, processing, summarizing and reporting, on a
          timely basis, information required to be discussed by us in the
          reports we file or submit under the Exchange Act." Please clarify that
          your disclosure controls and procedures also are effective to ensure
          that information required to be disclosed in the reports that you file
          or submit under the Exchange Act is accumulated and communicated to
          your management, including your principal executive and principal
          financial officers, to allow timely decisions regarding required
          disclosure. See rule 13a-15(e) of the Exchange Act. Alternatively, you
          may simply state that your disclosure controls and procedures are
          effective. In addition, please revise your disclosure in future
          filings.

<PAGE>

Mr. Larry Spirgel
December 07, 2005
Page 2

     RESPONSE

          As we have previously publicly disclosed, the company's former
          directors were replaced with the current directors on July 27, 2005,
          the company's former officers were replaced with current officers on
          August 25, 2005, and the former directors and officers of the
          company's subsidiary, BrT, were replaced with its current directors
          and officers on September 30, 2005. Although current management has
          undertaken, during the three months since its appointment, an
          intensive review of the business, financial condition and prior
          financial statements of the company and its subsidiaries, current
          management is not in a position to make any clarifying statements to
          the staff with respect to prior management's conclusions about the
          effectiveness of the company's disclosure controls and procedures as
          of December 31, 2004. We are able, however, to confirm that the
          company's future filings on Form 20-F will contain a statement as to
          management's assessment of the effectiveness of the company's
          disclosure controls and procedures, as suggested by the staff's
          comment.

     2.   We note your disclosure that "there have been no significant changes
          in our internal control over financial reporting that occurred during
          the year ended December 31, 2004 that have materially affected, or are
          reasonably likely to materially affect our internal control over
          financial reporting" (emphasis added). Item 308(c) of Regulation S-K
          required the disclosure of any change in your internal control over
          financial reporting identified in connection with an evaluation
          thereof that occurred during your last fiscal quarter (or your fourth
          fiscal quarter in the case of an annual report) that has materially
          affected, or is reasonably likely to materially affect, your internal
          control over financial reporting. Please confirm for us that there was
          no change in your internal control over financial reporting that
          occurred during your fourth fiscal quarter in 2004 that has materially
          affected, or is reasonably likely to materially affect, your internal
          control over financial reporting, and provide the disclosure required
          by item 308(c) of Regulation S-K in future filings.

     RESPONSE

          Although current management has undertaken an intensive review of the
          business, financial condition and prior financial statements of the
          company and its subsidiaries, current management is not in a position
          to make any clarifying statements to the staff with respect to changes
          in the company's internal control over financial reporting during the
          year ended December 31, 2004. We are able, however, to confirm that
          the company's future filings on Form 20-F will contain all disclosures
          required by Item 308(c).

     Note 8. Net non-operating expenses, page F-18
     ----------------------------------------------

<PAGE>

Mr. Larry Spirgel
December 07, 2005
Page 3

     3.   Clarify for us the nature of the loss of R$51.6 million on your
          investment in VANT Telecomunicacoes S.A. Tell us how you originally
          accounted for the amount deposited in a collateral account as a
          guarantee for the option to the purchase agreement. In addition,
          clarify how you accounted for the acquisition of the remaining
          interest in 2004 for U.S. GAAP reporting purposes.

     RESPONSE

          During 2001, our subsidiary was in the process of negotiating the
          acquisition of the controlling interest of Vant Telecomunicacoes S.A
          ("Vant") with AESCOM Sul Ltda ("AESCOM"). However, as a result of a
          restriction of the General Concession Plan ("PGO") of the
          Telecommunication Ministry which was in effect at that time, BrT was
          not allowed to exercise significant influence over or control another
          specialized network service provider in Brazil.

          Consequently, on December 5, 2001, BrT purchased only 19.9% of the
          interests in Vant. As BrT did not have the ability to exercise
          significant influence over the operating and financial policies of
          Vant, BrT did not apply the equity method to this investment for
          Brazilian GAAP or US GAAP purposes (APB 18, paragraph 17), but rather
          used the cost method of accounting for investments. This investment
          was excluded from the scope of SFAS 115 - Accounting for Certain
          Investments in Debt and Equity Securities as fair value was not
          readily determinable.

          Additionally, BrT agreed, on the date of the acquisition described
          above, to make a deposit equivalent to the purchase price of the
          remaining interests in Vant in an escrow account. In accordance with
          the terms of the agreement, until the end of 2004 AESCOM would have
          the right to sell to BrT the remaining capital of Vant (at a selling
          price equal to the escrow account deposit) in case the restriction on
          ownership by BrT was withdrawn. As management could not foresee
          whether the restriction would be withdrawn or if AESCOM would be
          definitely interested in selling its controlling interest, this
          deposit, placed in an escrow account, and which would be fully
          refundable in case the acquisition was not consummated by the end of
          2004, was recorded as a long-term asset (please see note 15-Other
          assets).

          In May 2004, the restriction of the PGO was withdrawn and AESCOM sold
          its remaining interest to BrT (the selling price equal to the escrow
          amount). Consequently, BrT's management applied the requirements of
          SFAS 141 - Business Combinations, including those related to step
          acquisitions (applied to the stake acquired in December 2001),
          generating goodwill on the acquisition amounting to R$65.8 million.

          Subsequently, management identified indicators in Vant's business plan
          that the carrying amount of the unit could not be recoverable and
          applied the impairment test as defined in SFAS 142 - Goodwill and
          Other Intangible Assets. As a result, an impairment loss for the full

<PAGE>

Mr. Larry Spirgel
December 07, 2005
Page 4

          amount of the goodwill, i.e., R$65.8 million, has been recorded
          (R$51.6 as "Net non-operating expenses - Losses on investments" and
          R$14.2 million as "Net non-operating expenses - Other").

          BrT's management was not aware that the restrictions of the PGO would
          be lifted prior to May 2004 nor was aware of any indication that this
          investment could be impaired before the acquisition of the controlling
          interest which took place in May 2004. It is worth to mention that
          BrT's management had very limited financial information prior to this
          acquisition from the time of entering into the agreement to purchase
          in December 2001 until May 2004. Consequently, a reliable fair value
          measurement was not possible before that time, as the range of
          reasonable fair value estimates was significant and the probability of
          the various estimates could not be reasonably assessed. BrT only had a
          post-2001 opportunity to accurately assess this investment after the
          acquisition was consummated, when BrT obtained access to Vant's books
          and recorded several adjustments which resulted in the impairment of
          this investment in 2004.

     Note 18. Intangibles, page F-26
     -------------------------------

     4.   Refer to footnote (a). Explain for us in more detail your accounting
          treatment for the goodwill associated with the merger of CRT.
          Specifically, tell us how you account for the usage of the deferred
          tax assets, discussed at page F-20, and the issuance of shares to the
          controlling shareholder corresponding to the realized tax benefit,
          discussed at page F-44. In addition, clarify the nature of the
          goodwill recorded as an intangible asset relating to the merger of CRT
          and the relationship of this asset to the deferred tax asset recorded
          for this transaction. You may wish to provide us with example journal
          entries to illustrate your accounting treatment for each of these
          transactions. Also, tell us whether you have recorded any reconciling
          items associated with these transactions for U.S. GAAP reporting
          purposes and tell us your basis in the U.S. GAAP literature for your
          accounting treatment.

     RESPONSE

          ACCOUNTING FOR THE ACQUISITION OF CRT - BRAZILIAN GAAP
          ------------------------------------------------------

          On July 31, 2000, Brasil Telecom Participacoes S.A. (BrTP) and its
          subsidiary Brasil Telecom S.A. (BrT) signed a contract for the
          purchase of all shares of TBS Participacoes S.A. (TBS), the holding
          company of Companhia Riograndense de Telecomunicacoes (CRT). TBS held
          the control of CRT represented by 85.19% of its common shares (31.56%
          of CRT's total capital). The price paid in cash on August 4, 2000 was
          R$ 1,517.5 million, of which R$ 1,499.8 million (98.83%) was paid by
          BrT and R$ 17.8 million (1.17%) by BrTP. The amount paid resulted in
          goodwill of R$ 768.0 million at the date of acquisition, by Brazilian
          GAAP (Journal Entry 1 of Exhibit 2.1).

<PAGE>

Mr. Larry Spirgel
December 07, 2005
Page 5

          Effective December 1, 2000, BrT acquired the minority interest of CRT
          through the exchange of its outstanding shares with 69,312,979 new
          shares issued by BrT. The acquisition of the minority interest was
          recorded on December 1, 2000 at such book value. Accordingly, the
          results of operations of BrT include the CRT minority interest
          acquired for periods subsequent to December 1, 2000.

          On November 30, 2000, a series of corporate acts was approved which
          resulted in the merger of CRT on December 28, 2000 (effective December
          1, 2000). The restructuring process was performed in accordance with
          Instructions No. 319/99 and 320/99 of the Brazilian Securities
          Commission (CVM) (Journal Entry 2 of Exhibit 2.1). In summary, the
          merger occurred as follows:

          a) Acquisition of a special-purpose company named 5265 Participacoes
          Ltda.;

          b) Assignment of shares of TBS Participacoes S.A. by BrTP and BrT to
          5265 Participacoes Ltda.;

          c) Merger of 5265 Participacoes Ltda. into TBS Participacoes S.A.,
          with the dissolution of 5265 Participacoes Ltda.;

          d) Merger of TBS Participacoes S.A. into Companhia Riograndense de
          Telecomunicacoes - CRT with the dissolution of TBS Participacoes S.A.;

          e) Merger of CRT into BrT with the dissolution of CRT. The services
          previously provided by CRT are now rendered by BrT through its CRT
          branch.

          This restructuring also comprised the push down of goodwill paid in
          the acquisition of the controlling shares of CRT, in order to
          guarantee tax deductibility of its amortization. As a consequence, a
          special reserve of goodwill (net of tax) was recorded at the CRT level
          in shareholders' equity. With the related tax benefit of the goodwill
          amortization recorded in a deferred tax asset in the amount of R$
          321.9 million (Journal Entry 2.b of Exhibit 2.1). As a result of this
          entry at the CRT level, in the BrT books goodwill was recomputed,
          reducing its amount to R$ 624.8 million by Brazilian Corporate Law (R$
          480.7 million by Brazilian GAAP - Journal Entry 2.c of Exhibit 2.1),
          which is recorded as intangible assets.

          The shareholders' meeting, which approved the merger mentioned above,
          gave minority shareholders of CRT the right to exchange their shares
          for BrT preferred and common shares. The exchange ratio was determined
          based on the market value of BrT's shares compared to the market value
          of each share of CRT.

          This merger resulted in the following new capital structure (in
          thousands of shares):

<PAGE>

Mr. Larry Spirgel
December 07, 2005
Page 6

<TABLE>
<CAPTION>
BRT - BEFORE THE MERGER OF CRT

                                        COMMON               PREFERRED
         SHAREHOLDERS                   SHARES                SHARES                TOTAL            %
--------------------------------   -------------------   -------------------  ------------------   ------
<S>                                       <C>                   <C>                 <C>               <C>
Controlling Shareholder                   229,132,204           116,042,516         345,174,720       75
Minorities                                  2,375,972           115,465,660         117,841,632       25
                                      ---------------       ---------------    ----------------     ----
Total                                     231,508,176           231,508,176         463,016,352      100
                                      ===============       ===============    ================     ====

SHARES ISSUED BY BRT

                                        COMMON               PREFERRED
         SHAREHOLDERS                   SHARES