SecProbe.io

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Mail Stop 6010

      September 27, 2005

Via U.S. Mail and Facsimile to (503) 721-1300

Michael K. Smith
Chief Financial Officer
NMHG Holding Co.
650 NE Holiday Street, Suite 1600
Portland, OR 97232

	Re:	NMHG Holding Co.
		Form 10-K for the Fiscal Year Ended December 31, 2004
		Filed March 15, 2005
	Form 10-Q for the Fiscal Quarters Ended March 31, 2005 and
June 30, 2005
      File No. 333-89248

Dear Mr. Smith:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  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 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 fiscal year ended December 31, 2004

Note 2. Significant Accounting Policies, page F-8

Revenue Recognition

1. We note that you recognize revenue at the time of shipment to
the
dealers.  Please describe the significant terms of your agreements
with dealers, including payment, return, exchange, and other
significant matters.   Explain and support why you believe it is
appropriate to recognize revenue upon shipment of product to
dealers.
We are particularly concerned about your financing terms, your
payment
terms, and the use of any interest-free periods.

2. In this regard, tell us if there are any cancellation
provisions in
dealer`s contracts (either for cancellation of purchases or for
cancellation of the relationship).  If so, tell us if you have
repurchase obligations under these circumstances.  Discuss the
frequency with which such cancellations occur and estimate the
dollar
amounts of the repurchases in your response, if material.  In
addition, advise us of any situations, conditions or circumstances
in
which a dealer has been unable to pay.  Explain the outcome of
these
situations and indicate the frequency with which they occur.

Note 16. Equity Investments and Related Party Transactions, page
F-35

3. We note that there was a decrease in the fees charged by NACCO
in
2004 versus 2003 due to "temporary suspensions" of the fees in
2004.
Please tell us more about why the fees were suspended.  Explain
the
services that NACCO performs on behalf of the company.  Confirm
that
your historical income statement reflects all costs of doing
business,
including costs incurred by NACCO on your behalf.  Refer to SAB
Topic
1-B for guidance.

	In connection with responding to our comments, please
provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* 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
* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in our review of your filing or in response
to
our comments on your filing.

      You may contact Kevin Kuhar, Staff Accountant, at (202) 551-
3662
or me at (202) 551-3554 if you have questions regarding these
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Martin James, Senior Assistant Chief
Accountant, at (202) 551-3671.

								Sincerely,

								Angela Crane
								Branch Chief

Michael K. Smith
NMHG Holding Co.
September 27, 2005
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