SecProbe.io

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								September 24, 2004

Jennifer L. Boatwright
Foley & Lardner LLP
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202-5306

      RE:	Intrepid Capital Management Funds Trust
      Registration Statement File Nos. 333-118634 and 811-21625

Dear Ms. Boatwright:

	We have reviewed the registration statement of Form N-1A for
the
Intrepid Capital Fund, filed with the Securities and Exchange
Commission on August 27, 2004.  We have the following comments:

PROSPECTUS

What are the Fund`s Principal Investment Strategies? (Page 2)
1. The prospectus states, "The Fund`s investments in high yield
securities typically will be in securities having a duration of
three
to five years at the time of purchase rated B or BB (or Ba) by a
nationally recognized rating agency."  (Emphasis added.)  Please
provide an example of duration.  For example, a fund with a
duration
of 5 would likely drop 5% in value if interest rates rose one
percentage point.  In addition, please disclose any quality or
duration limits for the Fund`s investments in high yield
securities.

Principal Risks
2. Because the adviser does not have experience in managing a
regulated investment company, please include the lack of
experience
as a principal risk to the Fund.

Fee Table
3. As shown in the fee table, other expenses are estimated to be
1.74% of the net assets of the Fund.  Please supplementally
explain
the breakdown of other expenses.

4. If the adviser intends to seek reimbursement from the Fund for
advisory fees waived and/or expenses reimbursed, please so state
in a
footnote to the fee table on page 4.  In addition, include that
information in the Statement of Additional Information on page B-
13.

Management of the Fund
5. On page 6, pursuant to Form N-1A Item 5, please state the
adviser`s fee as a percent of average net assets including any
breakpoints.

6. Please expand the description of the adviser and include the
amount of experience as an investment adviser as well as the
current
assets under management.

Historical Performance of Investment Advisory Accounts Managed by
the
Adviser (page 6)
7. The prior performance must present the average annual total
return
for 1, 5, and 10 years of operation or since date of inception if
less than 10 years. (Disclose the inception date).  Performance
may
be presented in other formats if it is accompanied by the average
annual total return for 1, 5 and 10 years.

8. The prospectus states, "All returns are time-weighted total
rate
of return and include the reinvestment of dividends and interest.
The
performance data for the Balanced Accounts is net of investment
advisory fees and expenses."  Please represent whether or not the
standardized SEC method was used to calculate the prior
performance.
If the standardized SEC method was not used to calculate the prior
performance, the Fund should disclose how the performance was
calculated and that the method differs from the standardized SEC
method.  Also, please confirm supplementally that the managed
portfolios did not charge a sales load.

9. Footnote (3) states, "The Combined Index consists of an
unmanaged
portfolio of 60% common stocks represented by the S&P 500 Index
and
40% bonds represented by the Citigroup High Yield Short-Term
Index."
Please explain supplementally who is calculating the combined
index
return and why the combined index is an appropriate index for the
Fund.

10. The prospectus states, "The performance information for the
Balanced Accounts has been examined in accordance with the Level
II
verification procedures of the Association for Investment Research
and Management."  Since the performance presentation states that
it
was audited or verified, please disclose who conducted the
audit/verification. Also, the Fund must include in its
registration
statement a consent for the audit/verification.

The Fund`s Share Price
11. On page 7 it states "the Fund will process purchase orders and
redemption orders that it receives in good order prior to the
close
of regular trading on a day that the New York Stock Exchange is
open
at the net asset value determined later that day."  Please define
"good order."

12. Pursuant to Item 6 of Form N-1A, please provide a brief
explanation of the circumstances under which the Fund will use
fair
value pricing and the effects of using fair value pricing.

Other Redemption Considerations
13. On page 15 it states, "if you purchased shares by check or
Electronic Funds Transfer, the Fund may delay the payment of
redemption proceeds until it is reasonably satisfied the check and
transfer of funds have cleared (which may take up to 15 days from
the
date of purchase)."  It should state that it may take up to 10
days.

STATEMENT OF ADDITIONAL INFORMATION

Cover Page
14.  Pursuant to the instruction for Item 9(a) of Form N-1A,
please
provide a toll free number or explain that a person interested in
obtaining a prospectus or SAI may call collect.

Trustee Approval of Investment Advisory Agreement (page B-11)
15. Please revise the disclosure so as to discuss all of the
material
factors considered by the Board.  Do not merely list the issues.
The
discussion should relate the issues to the specific circumstances
of
the registrant and the Investment Adviser.  Describe in reasonable
detail the decisions reached by the Board that formed the basis of
its decision to approve the contract.  Avoid conclusory
statements.
See Item 18.13 of Form N-2 and the discussion in Release No. IC-
24816, "Role of Independent Directors of Investment Companies,"
(February 15, 2001).

Proxy Voting Policy (page B-11)
16. Please supplementally explain the apparent inconsistencies
between the proxy-voting policy for the Fund, delegating the
responsibility to the adviser, and the adviser`s stated proxy-
voting
policy appearing on its website.

GENERAL

17. We note that portions of the filing are incomplete.  We may
have
additional comments on such portions when you complete them in a
pre-
effective amendment, on disclosures made in response to this
letter,
on information supplied supplementally, or on exhibits added in
any
pre-effective amendments.

18. Please advise us if you have submitted or expect to submit an
exemptive application or no-action request in connection with your
registration statement.

19. Response to this letter should be in the form of a pre-
effective
amendment filed pursuant to Rule 472 under the Securities Act.
Where
no change will be made in the filing in response to a comment,
please
indicate this fact in a supplemental letter and briefly state the
basis for your position.

TANDY LETTER

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the Fund and its management are in
possession of all facts relating to the Fund`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Notwithstanding our comments, please furnish a letter
acknowledging that
* Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* The Fund may not assert this action as 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 Investment Management in connection with our review of
your filing or in response to our comments on your filing.

   We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.

		*		*		*		*

      If you have any questions about these comments, please call
me
at 202-942-0542.

      							Sincerely,

      							Laura E. Hatch
      							Staff Accountant
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Ms. Jennifer L. Boatwright
September 24, 2004
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