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 May 22, 2025

Brent W. Clum
Chief Financial Officer
TXO Partners, L.P.
400 West 7th Street
Fort Worth, Texas 76102

 Re: TXO Partners, L.P.
 Form 10-K for the Fiscal Year ended December 31, 2024
 Filed March 4, 2025
 File No. 001-41605
Dear Brent W. Clum:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2024
Business and Properties
Proved Undeveloped Reserves (PUDS), page 10

1. Please expand your description of investments and progress made to
develop your oil
 and gas reserves to clarify how the individual costs relate to the
activities described,
 similar to your disclosure on page 8, and to separately report the
capital expenditures
 incurred to convert proved undeveloped reserves to proved developed
reserves.

 However, for any years in which you did not convert proved undeveloped
reserves to
 developed reserves, it appears you would report that such capital
expenditures were
 $0, to comply with the disclosure requirements in Item 1203(c) of
Regulation S-K.

Developed and Undeveloped Acreage, page 14

2. We note that while your estimates of proved undeveloped reserves
represent
 approximately 11% of total proved reserves as of December 31, 2024, the
table on
 May 22, 2025
Page 2

 page 15 indicates that you have virtually no undeveloped acreage
(representing about
 1/10 of 1% of total developed and undeveloped acreage).

 However, acreage held by production that includes acres on which wells
have not
 been drilled or completed should be considered undeveloped, regardless
of whether
 such acreage contains proved reserves, as expressed in your disclosure
towards the
 end of page 14, and consistent with Item 1208(c)(4) of Regulation S-K

 Please revise your disclosures of acreage to comply with Items 1208(a)
and 1208(b)
 of Regulation S-K, or if you believe that your current disclosures are
appropriate and
 that revisions are not needed, tell us how you have formulated this
view.

3. Please expand the disclosure relating to your developed and undeveloped
acreage to
 provide the expiration dates of material concentrations of your
undeveloped acreage.
 To the extent that you do not have material amounts of expiring acreage,
please
 include an explanation similar to the disclosure on page 18 stating
substantially all of
 our leases are held by production and do not require continuous
development if
 applicable, to comply with Item 1208(b) of Regulation S-K.

Financial Statements
Note 18 - Supplementary Financial Information for Oil and Gas Producing
Activities
Proved Reserves, page F-23

4. Please expand your discussion of the changes in total proved reserves
due to
 extensions and discoveries to explain the reason there are no
corresponding additions
 in proved undeveloped reserves in the reconciliation presented on page
10.

 For example, indicate the extent to which the reserve additions are
attributable to
 drilling wells that did not have any proved undeveloped reserves
assigned at the
 beginning of the year, and which resulted in additional proved developed
reserves.

 Please refer to FASB ASC 932-235-50-5 if you require further guidance.

Standardized Measure of Discounted Future Net Cash Flows Relating to Proved
Reserves,
page F-24

5. We note that the relative significance of your estimates of future
production and
 development costs utilized in computing the Standardized Measure for the
year ended
 December 31, 2024 appear to be materially inconsistent with the
corresponding costs
 utilized in each of the two previous years.

 Please revise your disclosure to address this apparent inconsistency or
tell us why you
 believe that revisions are not needed, if this is your view.
 May 22, 2025
Page 3

6. We note there is disclosure on page 3 of the reserves report at Exhibit
99.1 indicating
 that you may have directed the third party engineer to exclude the cost
of plugging
 and the salvage value of equipment at abandonment in its evaluation.

 Please expand your disclosure in Note 19 to clarify the reason for the
significant
 difference between the estimates of the undiscounted future net cash
flows excluding
 future income tax presented in Exhibit 99.1 and the estimates presented
on page F-24.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact John Hodgin at 202-551-3699 if you have questions
regarding the
engineering comments. Please contact Karl Hiller, Branch Chief, at 202-551-3686
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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