SecProbe.io

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                             SHEARMAN & STERLING LLP

                           FARIA LIMA FINANCIAL CENTER
                       AVENIDA BRIGADEIRO FARIA LIMA, 3400
                             04538-132 SAO PAULO--SP
                                     BRAZIL
                                +55 11 3702-2200

WRITER'S DIRECT NUMBER:
(55) 11 3702 2227

WRITER'S EMAIL ADDRESS:
sfrautschi@shearman.com

August 17, 2005

BY EDGAR AND FACSIMILE
----------------------

Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549-0405
Fax: (202) 772-9205

                       Telemig Celular Participacoes S.A.,
                       -----------------------------------
                 Form 20-F for the year ended December 31, 2004
                 ----------------------------------------------
                               File No. 001-14483
                               ------------------

Dear Mr. Spirgel:

         Telemig Celular Participacoes S.A., (the "Company") has received the
Staff's comment letter dated July 26, 2005 concerning the above-referenced
filing on Form 20-F. On behalf of the Company, we advise you as follows
regarding your comments as noted below:

SEC Comment No. 1.
------------------

We note that your chief executive officer and chief financial officer concluded
that your disclosure controls and procedures were "effective to ensure that
material information relating to us was made known to them by others within our
company particularly during the period in which this annual report and accounts
was being prepared." Please confirm for us that your disclosure controls and
procedures are effective in ensuring that information required to be disclosed
in the reports that you file or submit under the Exchange Act is recorded,
processed, summarized and reported, within the time periods specified in the
Commission's rules and forms and are effective in ensuring 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,

  Shearman & Sterling LLP is a limited liability partnership organized in the
  United States under the laws of the State of Delaware, which laws limit the
                        personal liability of partners.

<PAGE>

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.

Response to Comment No. 1.

The Company confirms that management, with the participation of the CEO and CFO,
evaluated the effectiveness of the Company's disclosure controls and procedures
as of December 31, 2004. Based on this evaluation, the CEO and CFO have
concluded that the Company's disclosure controls and procedures were effective
to provide reasonable assurance that information required to be disclosed by the
Company in the reports it files or submits under the Exchange Act is recorded,
processed, summarized and reported, within the time periods specified in the
Commission's rules and forms, and is accumulated and communicated to management,
including the CEO and CFO, to allow timely decisions regarding required
disclosure. As requested, the Company will revise its disclosure in future
filings to better reflect its compliance with Rule 13a-15(e).

SEC Comment No. 2.
------------------

We note your disclosure that "there were no significant changes in our internal
controls or in other factors that could significantly affect these controls and
procedures subsequent to the date our chief executive officer and our chief
financial officer completed their evaluation, no were there any significant
deficiencies or material weaknesses in our internal controls requiring
corrective actions" (emphasis added). Item 308(c) of Regulation S-K requires 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 to Comment No. 2.

The Company confirms that there was no change in its internal control over
financial reporting that occurred during its 2004 fiscal year that has
materially affected, or is reasonably likely to materially affect, its internal
control over financial reporting. As requested, the Company will revise its
disclosure in future filings to better reflect the disclosure required by Item
308(c) of Regulation S-K.

SEC Comment No. 3.
------------------

It appears that the captions "cost of services" and "gross profit" exclude
depreciation and amortization for property and equipment directly attributed to
the generation of revenue. If so, we believe that this presentation
inappropriately reports a figure for income before depreciation and
amortization. As required by SAB 11:B, revise your presentation in future
filings to either

                                                                               2

<PAGE>

reclassify the applicable depreciation to "cost of services" or remove the
caption "gross margin" and indicate the amount of applicable depreciation that
is excluded from "cost of services."

Response to Comment No. 3.

Consistent with SAB 11:B, the Company will remove the caption "Gross margin" and
indicate the amount of applicable depreciation excluded from "Cost of services"
in future filings.

SEC Comment No. 4.
------------------

Tell us how you considered the guidance in EITF 01-14 in determining that it is
appropriate to present revenues net of each of the taxes on telecommunications
services that are described at page 28.

Response to Comment No. 4.

The Company has followed guidance provided by EITF 01-14 in presenting revenues
net of taxes on telecommunications services. The taxes that have been netted
against gross revenues include ICMS (Tax on Circulation of Goods and Services),
PIS (Social Integration Program) and COFINS (Contribution to Financing Social
Security). These taxes are determined on a value-added basis (taxes paid on
allowable inputs are offset against taxes determined upon sale to the Company's
customers) and are passed directly on to the Company's customers. Based on the
collective weight of the EITF 99-19 indicators (placing an emphasis on the
primary obligor indicator) the Company submits that the characterization of
reimbursements received for these expenses incurred as revenue is appropriate.

FUST (Contribution for the Fund for Universal Access to Telecommunications
Services) and FUNTTEL (Contribution for the Fund of Telecommunications
Technological Development) are imposed on certain operating revenues after
deduction of the value-added taxes mentioned above and discounts. These two
taxes may not be passed directly on to customers.

The other tax on telecommunications services, called FISTEL (Telecommunication
Inspection Fund), consists of two types of fees: (i) a fee assessed on
telecommunication stations upon the issuance of their authorization
certificates; and (ii) an annual operations inspection fee that is based on the
number of authorized stations in operation at the end of the previous calendar
year. FISTEL may not be directly passed on to customers.

Therefore, FUST, FUNTTEL and FISTEL taxes are levied directly on the Company's
operations and are included in "Cost of services."

SEC Comment No. 5.
------------------

Explain for us in more detail your accounting treatment for the future tax
benefits associated with the legal reorganization whereby Telpart contributed
assets to you. Specifically, clarify how you account for the usage of the
deferred tax assets and the issuance of shares to Telpart for the amount of the
tax benefits recognized. In addition, tell us whether this transaction relates
to the capitalization of retained earnings, discussed at page F-20. Clarify your
statement that this

                                                                               3
<PAGE>

capitalization does not involve the issuance of additional shares. Tell us the
effect, if any, of each of these transactions on your earnings per share
calculation under SFAS 128.

Response to Comment No. 5.

On December 27, 1999, as permitted by Article 157 of Brazilian Corporate Law and
Instructions N(degree). 31/84, 319/99 and 320/99 of the Comissao de Valores
Mobiliarios, or CVM (the Brazilian Securities Commission), Telpart Participacoes
S.A., a major shareholder of the Company, subscribed for and paid in, through
transfer of its investment and corresponding goodwill asset ("Goodwill") in the
Company, 100% of the capital in a new entity, called "27 de Agosto Participacoes
S.A."

The objective of the down-stream merger, or the legal reorganization, was to
assure realization of the tax benefits arising from the amortization of the
Goodwill paid over book value of R$636,772 thousand on its acquisition of shares
of the Company by transferring to the Company the tax benefit arising from the
amortization of the Goodwill. The purchase consideration included 64,405,151,125
shares in the Company and the corresponding Goodwill. The down-stream merger of
27 de Agosto Participacoes S.A. was approved by the shareholders on December 28,
1999, whereupon 27 de Agosto Participacoes S.A was merged into the Company. In
the down-stream merger, the shareholders of Telpart Participacoes S.A., received
shares of the Company in exchange for their shares in 27 de Agosto Participacoes
S.A. .

Under Brazilian GAAP and Brazilian Corporate and Tax Law, goodwill is generally
not tax deductible and represents the difference between consideration paid and
the book and tax value of the underlying assets. By effecting a downstream
merger, the goodwill is converted to a deferred asset (`Deferred charge'), which
is tax deductible. This transaction does not change the Brazilian or US GAAP
book basis, though it does increase the tax basis of the assets.

For US GAAP purposes, in accordance with EITF 94-10, tax effects caused by
transactions with shareholders are not included in the Company's statement of
operations but rather in equity. Therefore, the Company recorded a deferred tax
asset of R$ 212,045 thousand with an offsetting amount recorded in Capital
reserve. The deferred tax asset will be realized as the tax benefits are
recognized for local tax purposes over a period of up to 10 years.

In accordance with Brazilian Corporate law, the Company may issue shares (pro
rata both common and preferred) based on the different pricing criteria
permitted by such law to the contributing shareholder for the amount of the tax
benefits recognized by the Company. However, the minority shareholders will be
given the right to purchase their pro rata share of this capital stock increase
in order to prevent dilution. In the event the minority shareholders do not
exercise their preemptive rights, these shares will be issued to the majority
shareholders.

These potential shares are considered contingent shares and since it is not
possible to determine the pricing criteria the Company will use, these shares
are not included in either basic or diluted earnings per share calculation, in
accordance with SFAS 128.

This transaction does not relate to the capitalization of retained earnings
mentioned in Note 8 (a) in the financial statements.

                                                                               4
<PAGE>

A typographical error in the second paragraph of Note 8 in the financial
statements led to the Company's assertion that "such capitalization increased
the number of shares outstanding but did not involve issuance of additional
shares." This should have read, "such capitalization did not increase the number
of shares and did not involve issuance of additional shares." The issuance of
shares included in the Company's flux of the number of shares on Note 8(a)
relates to capitalization of Capital Reserves mentioned in Note 8 (e).

SEC Comment No. 6.
------------------

We note your disclosure that R$14,030 of the provision relating to ICMS tax was
reversed to selling, general and administrative expenses in 2004, while the
accrual for this contingency decreased by R$57,726 from R$69,021 at December 31,
2003 to R$11,295 at December 31, 2004. Tell us and disclose, in future filings,
how you accounted for the remainder of the decrease. Similarly, tell us and
disclose where you recorded the increase in your provision for the FISTEL fund
from R$13,063 at December 31, 2003 to R$34,227 at December 31, 2004.

Response to Comment No. 6.

The comment above relates to Tele Norte Celular Participacoes S.A., a related
party, and is discussed in a response relating to comments it received from you.
Tele Norte Celular Participacoes S.A. has responded to the comment in its
response letter dated the date of this letter.

SEC Comment No. 7.
------------------

Tell us your basis for offsetting the fair value of your swap assets and
liabilities, rather than presenting the assets and liabilities on a gross basis.

Response to Comment No. 7.

Note 16 to the financial statements disclosed the fair value of total assets and
liabilities related to cross-currency rate swap agreements and the net
unrealized results. Although the unrealized gain and losses of the individual
swap contracts were presented on the balance sheet on a net basis, the fair
values of such contracts were presented on a gross basis, segregating assets and
liabilities as follows:

<TABLE>
<CAPTION>
                                                                                        December 31,
                                                           ------------------------------------------
                                                                        2004                    2003
                                                           ------------------  ----------------------
<S>                                                                   <C>                      <C>
Current assets
Investment - cross currency interest rate swap                        16,776                   6,929

Non-current assets
Investment - cross currency interest rate swap                         3,098                  59,224

Non-current liabilities
 Cross currency interest rate swap                                     1,826                       -
</TABLE>

                                                                               5
<PAGE>

<TABLE>
<CAPTION>

                                                           ------------------  ----------------------
<S>                                                                   <C>                     <C>
Net investment - swap agreements                                      18,048                  66,153
                                                           ------------------  ----------------------

                                                           ==================  ======================
</TABLE>
The individual swap contracts are designed to exchange the risk of holding a US
dollar fixed interest instrument for a Brazilian Real variable interest (CDI)
instrument. This compound