Mail Stop 4561





November 18, 2005


By U.S. Mail and facsimile to (423) 623-6020.

Richard G. Harwood
President and Chief Executive Officer
United Tennessee Bankshares, Inc.
170 West Broadway
Newport, TN 37821

Re:	United Tennessee Bankshares, Inc.
Form 8-K
	Filed November 14, 2005
	File No. 000-23551

Dear Mr. Harwood:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with more
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.
1. It appears from your disclosure that you should be filing the
information related to the non-reliance on previously issued
financial statements under Item 4.02(a) of Form 8-K.  If so,
please
revise your filing accordingly.  If not, please provide the
following
required disclosures related to Item 4.02(b):
* State the date on which you were advised by your independent
auditors that your previously issued financial statements should
not
be relied upon.
* Specifically state whether your description of the circumstances
underlying your conclusion that previously issued financial
statements included in your filing was provided to you by your
independent accountant.  If not, please include a brief
description
of the information provided to you by your independent accountants
that led to your decision that your previously issued financial
statements could no longer be relied upon.
* Please amend your previously filed Form 8-K to include the
independent accountant`s letter as an exhibit to the filed Form 8-
K
no later than two business days after your receipt of the letter.
2. You state that your financial statements for the years ended
December 31, 2003 and 2004 and the interim period ended June 30,
2005
should not be relied upon.  If you also believe that your
financial
statements included in your March 31, 2005 Form 10-Q should not be
relied upon, please revise to state so.  If not, please state why
not.
3. We note that you intend to file restated financial statements.
Please tell us how and when you will file them.

* * * * *

       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
provide
us with a response.  You may wish to provide us with marked copies
of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
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 comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* 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 comments as a 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 Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Rebekah Moore, Staff Accountant, at (202)
551-
3463 or me at (202) 551-3423 if you have questions.

Sincerely,



Amit Pande
Assistant Chief Accountant
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Richard G. Harwood
United Tennessee Bankshares, Inc.
November 17, 2005
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