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Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   December 23, 2005  Mr. James R. Gober President and Chief Executive Officer Infinity Property and Casualty Corporation 2204 Lakeshore Drive Birmingham, Alabama   35209
Re: Infinity Property and Casualty Corporation
 Form 10-K for Fiscal Year Ended December 31, 2004  Filed March 10, 2005
 File No. 000-50167
Dear Mr. Gober:

We have limited our review of your filing to those issues we have addressed in
our comments.  In our comments, we ask you to  provide us with information so we may
better understand your disclosure.  Please be as de tailed as necessary in  your explanation.
After reviewing this information, we may raise additional comments.
  Please understand that the purpose of our re view 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.

Item 7.  Management’s Discussion and Anal ysis of Financial Condition and …, page 16

 Critical Accounting Policies, page 16

 Insurance Reserves, page 17

1. We believe your disclosure in Management ’s Discussion and Analysis regarding the
insurance reserves could be improved to better explain the judgments and
uncertainties surrounding this estimate a nd the potential impa ct on your financial
statements.  We believe that disclosures explaining the likelihood that materially
different amounts would be reported under di fferent conditions or  using different
assumptions is consistent with the ob jective of Management’s Discussion and

Mr. James R. Gober
Infinity Property and Casualty Corporation December 23, 2005 Page 2
 Analysis. In this regard, it  is unclear whether the 1% change you already disclose
represents a reasonably like ly, or hypothetical change .  Please provide us the
following information, in disclosure-type format , to help us evaluate the adequacy of
your disclosure.

a. Because IBNR reserve estimates are more imprecise, please provide the
amount of IBNR separately from case reserves.
b. Describe those assumptions that you believe are the most significant in
determining your loss reserves.  For ex ample significant assumptions could be
those assumptions that involve the greatest amount of judgment or those
assumptions that have the greatest financial impact on the loss reserve
balance.
c. Describe the methodologies used to determine your loss reserves.  For
example this might include a discussion of the various actuarial methods used
that may vary depending on the nature of the business underwritten.
d. It is our understanding of the propert y and casualty insurance industry that
companies will establish reserves either by the calculation of ranges around the reserves or by the calculation of point estimates.
i. If management calculates a range  in determining the loss reserve
recorded in the financial statements, describe the range of loss reserve
estimates, the factors that determin ed the boundaries of this range and
your basis for selecting the record ed amount rather than any other
amount within the range as the best  estimate of incurred losses.  In
addition include quantified and narrativ e disclosure of the impact that
reasonably likely changes in one or  more of these variables (i.e.
actuarially method and/or assumpti ons used) would have on reported
results, financial position and liquidity.
ii. If management calculates point estimates in determining the loss
reserve recorded in the financial st atements, disclose the following:

1. The various methods considered and the method that
was selected to calculate the reserves.  If multiple point estimates were generated, desc ribe the different values
for these point estimates.  Include a discussion of why the method selected was mo re appropriate over the
other methods and why one point estimate was selected instead of other point estimates.
2. Clarify whether the loss re serves recorded in the
financial statements are solely based on the point
estimate calculated or, if not, how that estimate is used. Quantify and describe the difference between what is recorded in the financial statements and the point estimate.

Mr. James R. Gober
Infinity Property and Casualty Corporation December 23, 2005 Page 3
 3. Include quantified and narrative disclosure of the
impact that reasonably likely changes in one or more of
the variables (i.e. actuarially method and/or  assumptions used) would have on reported results, financial position and liquidity.

2. On page 38, we noted that your loss re serves are based, in part, on “estimates
received from ceding reinsurers and insura nce pools and associations”.  As such,
please provide us, in disclosure  type format, the following:

a. The risks and uncertainties associated with these estimates and the actual
and expected effects of this uncer tainty on your financial position and
results of operations;
b. The dollar amount of reserves record ed based on information received
from the cedants and the nature and extent of the information received
from the cedants related to policies,  claims, unearned premiums and loss
reserves;
c. The time lag from when claims are reported to the cedant to when the
cedant reports them to you and whether,  how and to what extent this time
lag affects your loss reserve estimate;

d. The amount of any backlog relate d to the processing of assumed
reinsurance information, whether the b acklog has been reserved for in the
financial statements, and, if applicable , when the backlog will be resolved;

e. What process management performs  to determine the accuracy and
completeness of the information received from the cedants;
f. How management resolves disputes w ith cedants and how often disputes
occur;
g. How management uses the information received from the cedants in its
determination of its assumed loss reserves, and whether reinsurance
intermediaries are used to transact and service reinsurance policies and
how that impacts your loss re serving methodology; and

h. Whether management uses historical  loss information to validate its
existing reserves and/or as a means of noticing unusual trends in the
information received from the cedants.
Consolidated Financial Statements

Mr. James R. Gober
Infinity Property and Casualty Corporation December 23, 2005 Page 4
 Notes to Consolidated Financial Statements, page 36

 Contingencies, page 53

3. Please provide us, in disclosure-type format , disclosures that comply with paragraph
10 of SFAS 5, as you do not appear to give an  estimate of the possible loss or range
of loss or state that such an estimate cannot be made.

*    *    *    *

 Please respond to these comments within 10 business days or tell us when you
will provide us with a response.   Please furnish a letter that keys your responses to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please file your letter on E DGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing include all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;
• 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Mr. James R. Gober
Infinity Property and Casualty Corporation December 23, 2005 Page 5
 You may contact Ibolya I gnat, Staff Accountant, at  (202) 551-3656, or Oscar
Young, Senior Accountan t, at (202) 551-3622,  if you have questions regarding the
comments.  In this regard, do not hes itate to contact me, at (202) 551-3679.

Sincerely,    Jim B. Rosenberg Senior Assistant Chief Accountant