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    November 22, 2022

VIA EDGAR

    Ms. Christina DiAngelo Fettig

Senior Staff Accountant

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Miller Investment Trust

File No. 811- 22131

Dear Ms. Fettig:

This letter responds to comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “SEC”) to the filing by the Miller Investment Trust (the “Registrant”)
and its series (each a “Fund” and, collectively, the “Funds”) of the Registrant’s Form N-SCR for the fiscal
year ended October 31, 2021 and certain other filings, as provided verbally in a phone conversation on September 14, 2022 to Bibb Strench.
The Staff’s comments and our responses are discussed below.

Comment 1:	Form N-CSR. Please note
that Form N-CSR was updated recently by the SEC to, among other things, add paragraph (i) and (j) to Item 4 of the Form. Please represent
that future N-CSR filings will be made on the most up-to-date and effective Form N-CSR.

 Response: The Registrant represents that future N-CSR filings will be made on the most up-to-date and effective Form N-CSR.

Comment 2:	Form N-CSR. Please note
that Form N-CSR was updated recently by the SEC to revise paragraph 4(d) in the Instructions to Item 13(a)(2) and paragraph (b) of Item
11 of the Form to request information about internal

    Bibb.Strench@ThompsonHine.com   Fax: 202.331.8330   Phone: 202.973.2727
    bs

Ms. Christina DiAngelo Fettig

November 22, 2022

Page 2

controls “during
the period covered by this report.” Please re-file the annual report to revise the report to cover the full annual period now required
by Form N-CSR instead of the half-year period as reported.

 Response: The Registrant refiled an amended N-CSR on October 6, 2022 containing its financial statement so that the response noted in the comment
covers its full fiscal year of 2021. See https://www.sec.gov/cgi-bin/browse-edgar?company=miller+investment+trust&match=starts-with&filenum=&State=&Country=&SIC=&myowner=exclude&action=getcompany

There were
no significant changes in the Registrant’s internal control over financial reporting that occurred during the period covered by
this report that have materially affected, or are reasonably likely to materially affect, the Registrant’s internal control over
financial reporting.

Comment 3:	Prospectus. When the
amended N-CSR filing for the fiscal year ended October 31, 2021 is refiled, please make sure the certification required by Item 13 of
the Form are re-executed and contain the date of the filing or a date within several days of the filing.

 Response: The required certifications in the amended N-CSR, which was filed on October 6, 2022, were re-executed and dated the same as the filing.

Comment 4:	MD&A: The options transactions
for the Miller Convertible Plus Fund during the fiscal year ended October 31, 2021 impacted the Fund’s performance significantly.
It is the Staff’s expectations that when options or other derivatives transactions impact the performance of a mutual fund significantly,
the management discussion and analysis (“MD&A”) section of the annual report will contain a discussion of that impact.
Please represent that the MD&A section of the annual report in future N-CSR filings will have a fulsome discussion of options and/or
other derivatives transactions if such transactions materially impacted the performance of a Fund.

 Response: The Registrant represents that the MD&A section of the annual report in future N-CSR filings will have a fulsome discussion of
options and/or other

Ms. Christina DiAngelo Fettig

November 22, 2022

Page 3

derivatives transactions if such transactions materially impacted
the performance of a Fund during the reporting period.

Comment 5:	Performance Tables. The
Registrant presented performance of multiple classes of shares in the graphs in the Annual Report. Pursuant to Item 27(b)(7)(ii)(B) of
Form N-1A, the table and graph should be accompanied by the following statement, which was omitted:

“The graph and table to the effect that past performance
does not predict future performance and that the graph and table do not reflect the deduction of taxes that a shareholder would pay on
fund distributions or the redemption of fund shares.”

 Response: The Registrant represents that performance tables and graphs of annual reports in future N-CSR filings will include the above statement.

Comment 6: 	Schedule of Investments.
In the Schedule of Investments for each Fund, certain investments are zero coupon bonds. Please consider as a best practice showing the
yield or some other indicator of the rate at which the income of these instruments is realized.

 Response: The Registrant will consider adding to the Schedule of Investments in future annual reports some indicator of the rate of return of
its zero coupon bond investments.

Comment 7: 	Schedule of Investments.
In the Schedule of Investments for each Fund, synthetic convertible bond investments are discussed as a single investment. However, the
Notes to the financial statements indicated that a synthetic convertible bond investment consists of two securities, each with its own
market value: “Synthetic convertible bonds are financial instruments created by combining two or more separate securities.”
Please explain the basis for its presentation in the Schedule of Investments.

 Response: The annual report in future N-CSR filings will replace the above language about the synthetic convertible bond consisting of two securities
and instead contain an asterisk or similar mark cross referencing to the note to

Ms. Christina DiAngelo Fettig

November 22, 2022

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the financial statements describing the synthetic convertible
bonds as follows:

A synthetic convertible bond security is a
single security issued by an investment bank, broker-dealer or other financial institution that is designed to have the same attributes
of a convertible security had it been issued by the designated underlying company. Like ordinary convertible bonds, a synthetic convertible
bond is a fixed-income corporate debt security that yields interest payments with conversion features. Importantly, the credit rating
of a synthetic convertible bond is based on the issuing financial institution’s credit rating and not the underlying company.

Comment 8:	Notes. The following
disclosure is on page 40 of the Annual Report in the Summary of Significant Accounting Policies section:

“The notional value of the derivative instruments outstanding
as of October 31, 2021 as disclosed in the Schedule of Investments for Miller Convertible Plus Fund serves as an indicator of the volume
of derivative activity during the period.”

Please review this disclosure. It appears that the notional value
is much higher than the notional value as compared to past semi-annual and annual reports. Please confirm the accuracy.

 Response: The Registrant has reviewed the disclosure noted above and confirms that it is accurate.

Comment 9:	Prospectus/Annual Report.
The disclosure set forth in Note 3 of the annual report regarding the expense recapture pursuant to the Expense Limitation Agreement and
the disclosure in the prospectus regarding the expense recapture pursuant to the Expense Limitation Agreement are inconsistent. Going
forward, please make sure that the disclosure about expense recapture in these two filings are consistent.

 Response: The Registrant represents that disclosure about the expense recapture arrangement in the upcoming annual update of its prospectus
and

Ms. Christina DiAngelo Fettig

November 22, 2022

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statement of additional information will be consistent
with disclosure in the annual reports for the fiscal year ended October 31, 2022.

Comment 10: Section 4.08(b) of
Regulation S-X addresses assets of an issuer mortgaged, pledged, or otherwise subject
to lien. The Statement of Assets and Liabilities of the Miller Convertible Plus Fund shows the segregated cash for the collateral of the
loans. Section 4.08(b) requires the approximate amounts of assets pledged or otherwise subject to a lien, and the approximate amounts
thereof, be designated and the obligations collateralized briefly identified be disclosed. Please make sure the required disclosure is
made in a footnote in annual reports filed in future N-CSR filings.

 Response: The Registrant represents that the requested note will be added to the annual reports in future N-CSR filings.

Comment 11: Form N-CEN. Item B.8. of
Form N-CEN requires the Registrant to list each of its Trustees. Please note that Mr. Greg Miller is not included in the response to this
item. Please amend the Form N-CEN filing to include the required disclosure about Mr. Miller.

 Response: The Registrant refiled an amended N-CEN on October 6, 2022 listing Greg Miller. See https://www.sec.gov/cgi-bin/browse-edgar?company=miller+investment+trust&match=starts-with&filenum=&State=&Country=&SIC=&myowner=exclude&action=getcompany

Comment 12: Form N-PX. Registrant filed
Form N-PX on July 26, 2022 and filed its previous Form N-PX on August 6, 2021. Instruction F of that form requires that it be signed “by
its principal executive officer or officers.” Please note that the Form N-PX filed on July 26, 2022 was not signed by Greg Miller,
the Trust’s principal executive officer, but rather another officer. Please further note that the Form N-PX filed on August 6, 2021
appears to be incomplete, including missing the signature line.

 Response: Registrant filed amended Form N-PXs on October 24, 2022 and October 27, 2022 that reflect the requested corrections.

Ms. Christina DiAngelo Fettig

November 22, 2022

Page 6

*	*		*		*

If you have any additional comments or questions, please contact
the undersigned at (202) 973-2727.

Sincerely,

/s/ Bibb Strench

Bibb Strench

 cc: Michael Miller

Treasurer and Principal Financial Officer

Miller Investment Trust