SecProbe.io

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<TYPE>CORRESP
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<FILENAME>rmkaifcorresp.txt
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[LOGO] KIRKPATRICK & LOCKHART                    1800 Massachusetts Avenue, N.W.
                                                 Suite 200
                                                 Washington, D.C. 20036-1221
                                                 202.778.9000
                                                 202.778.9100 Fax
                                                 www.kl.com

                                November 5, 2004

Valerie J. Lithotomos
Senior Counsel
Office of Disclosure and Review
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC   20549

         Re:      RMK Advantage Income Fund, Inc. ("Fund")
                  (File Nos. 333-18846 and 811-21631)

Dear Ms. Lithotomos:

     This  letter  responds to the  following  comment,  which we received  from
Securities and Exchange Commission's staff by telephone:  Please discuss whether
it is  appropriate  to  include  "Advantage"  in the Fund's  name.  Below is our
response.

     Unlike  words such as  "Municipal"  or  "Mexican,"  we do not believe  that
including "Advantage" in the Fund's name suggests that the Fund will invest in a
particular type of security or employ a particular  strategy.  In fact, a number
of funds with different  investment  portfolios and strategies currently include
"Advantage" in their names.  For example,  Evergreen Income Advantage Fund, Inc.
is a closed fund with an investment objective of seeking a high level of current
income and a secondary  objective of seeking capital  appreciation to the extent
consistent  with its primary  investment  objective.  That fund invests in below
investment grade debt  securities,  loans and preferred  stocks.  Cohen & Steers
Advantage  Income Realty Fund Inc., on the other hand, is a closed end fund that
has a primary  investment  objective of providing  high current  income  through
investment in real estate  securities  and a secondary  investment  objective of
capital appreciation.  In addition, Alliance All-Market Advantage Fund Inc. is a
closed-end  fund with an  investment  objective  of long term  growth of capital
through all market  conditions.  That fund invests in a core portfolio of equity
securities of large companies.

     Nonetheless,  we note  that  the  Fund  has  certain  characteristics  that
distinguish it from other closed end funds. First, unlike many other high income
funds,  the Fund  has the  ability  to  invest  in  multiple  asset  categories,
including mortgage-backed securities, other asset-backed securities, REIT common
stocks, corporate bonds,  convertible debt securities,  foreign bonds, preferred
stocks,   municipal  securities  and  other  equity  securities.   Morgan  Asset
Management,  Inc., the Fund's investment adviser ("Adviser"),  believes that the
ability,  and intention,  to invest in a broad  universe of securities  provides
unique  opportunities and exposure for the Fund.  Second, the adviser utilizes a
"value"  investing  strategy  that is focused on issuers and not  macro-economic

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Valerie J. Lithotomos, Esq.
November 5, 2004
Page 2

factors.  The  Adviser  has an  experienced  research  staff that  analyzes  the
financial  and  business  fundamentals  of  particular  issuers,  as  opposed to
engaging in technical analysis of broad financial market factors and indicators.
This "issuer focused" value approach  provides greater  opportunity for the Fund
to realize capital gain.  Finally,  the Adviser  anticipates  that the Fund will
leverage  through a credit  facility or  commercial  paper  facility,  which the
Adviser  believes will enable the Fund to achieve maximum  flexibility  with the
lowest possible  transaction costs, if economic conditions warrant increasing or
decreasing  leverage  from time to time.  The  Fund's  ability  to  increase  or
decrease leverage quickly and at a low marginal cost distinguishes it from those
funds that leverage through  preferred stock or long-term  secured debt, both of
which  typically  require higher  transaction  costs and longer time horizons to
change.

     Due to the  characteristics  of the Fund described above, which the Adviser
believes  offer  potential  advantages  to  Fund  stockholders,  and  the use of
"Advantage" in other current funds, we do not believe there is any reason not to
include "Advantage" in the Fund's name.

     If you have any further  comments or  questions  regarding  this  response,
please contact  Arthur J. Brown at (202) 778-9046 or Jennifer  Gonzalez at (202)
778-9286. Thank you for your attention to this matter.

                            Sincerely,

                            /s/ Jennifer R. Gonzalez

                            Jennifer R. Gonzalez

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