Mail Stop 3561

      							August 18, 2005


Alvaro Pereira de Moraes Filho
Chief Executive Officer
TIM Participacoes S.A.
Rua Comendador Araujo, 299-3 0 andar
80420-000 Curitiba, PR, Brazil


	Re:	TIM Participacoes S.A.
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed June 30, 2005
		File No. 1-14491

Dear Mr. Filho:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Please address the following comments
in
future filings.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a future 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
information so we may better understand your disclosure.  After
reviewing this information, we may or may not 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.


Form 20-F for Fiscal Year Ended December 31, 2004

Item 15.  Controls and Procedures, page 89

1. We note your disclosure that your disclosure controls and
procedures are "effective to provide reasonable assurance that
information required to be disclosed in the reports we file and
submit under the Exchange Act is recorded, processed, summarized
and
reported as and when required."  Please clarify and disclose, in
future filings, that your disclosure controls and procedures also
are
effective to ensure that information required to be disclosed in
the
reports that you file or submit under the Exchange Act is
accumulated
and communicated to your management, including your principal
executive and principal financial officers, to allow timely
decisions
regarding required disclosure.  See Rule 13a-15(e) of the Exchange
Act.  Alternatively, you may simply state that your disclosure
controls and procedures are effective.

Note 33.  Reconciliation between Brazilian Corporate Law and US
GAAP,
page F-53

h.  Incorporation of tax benefit of goodwill by subsidiaries, page
F-
66

2. Explain for us in more detail how you account for the future
tax
benefit generated by the amortization of goodwill under US GAAP
and
Brazilian Corporate Law. In addition, clarify how you account for
the
issuance of shares to the controlling shareholder for the amount
of
the realized benefit and the effect of this transaction on your
earnings per share calculation under SFAS 128.  You may wish to
provide us with example journal entries to illustrate your
accounting
treatment for each of these transactions under both US GAAP and
Brazilian Corporate Law.

m.  Handset Discounts, page F-69

3. We note that you have recorded a reconciling item regarding the
treatment of handsets for US GAAP reporting purposes for the
fiscal
year ended December 31, 2004 as a result of EITF 00-21.  Tell us
your
basis in US GAAP for recording the discount on the handset as a
reduction in service revenue on a monthly basis prior to your
adoption of EITF 00-21.


Note 34.  Additional disclosures required by US GAAP, page F-70

a.  Condensed Consolidated Balance Sheets and Statements of Income
- -
US GAAP, page F-70

4. Tell us how you considered the guidance in EITF 01-14 in
determining that it is appropriate to present revenues net of
indirect taxes such as ICMS, PIS, and COFINS.

e.  Segment information, page F-82

5. Tell us how you applied the guidance in SFAS 131 in determining
that TIM Sul and TIM Nordeste were not separate operating
segments.



*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please file your response letter on EDGAR.  Please
understand that we may have additional comments after reviewing
your
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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Melissa Hauber, Staff Accountant, at (202)
551-
3368 or Carlos Pacho, Senior Assistant Chief Accountant, at (202)
551-3835 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3810
with any other questions.

								Sincerely,



								Larry Spirgel
								Assistant Director




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Alvaro Pereira de Moraes Filho
TIM Participacoes S.A.
August 18, 2005
Page 4