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                             June 1, 2023

       David Hsu
       Chief Executive Officer
       SolarMax Technology, Inc.
       3080 12th Street
       Riverside, CA 92507

                                                        Re: SolarMax
Technology, Inc.
                                                            Amendment No. 3 to
Registration Statement on Form S-1
                                                            Filed December 23,
2022
                                                            File No. 333-266206

       Dear David Hsu:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
January 12, 2023 letter.

       Amendment No. 5 to Registration Statement on Form S-1 filed on May 2,
2023

       Management   s Discussion and Analysis of Financial Condition and
Results of Operations
       Critical Accounting Policies
       Impairment of Long-Lived Assets and Goodwill, page 93

   1.                                                   We note your disclosure
that based on your annual impairment testing you determined the
                                                        estimated fair value of
our PRC reporting unit substantially exceeds its carrying value and
                                                        that there was no
impairment loss for the years ended December 31, 2022 and 2021. We
                                                        further note your
disclosure on page 87 that you have no pending agreement with SPIC or
                                                        any other customer for
your China segment during the year ended December 31, 2022 and
                                                        continuing through the
date of this prospectus, despite the fact that China has relaxed its
                                                        zero tolerance policy.
In light of your lack of revenues and continued losses in your China
 David Hsu
SolarMax Technology, Inc.
June 1, 2023
Page 2
      segment and lack of future customer agreements, please further describe
to us the results
      of your impairment test and how management was able to determine that the
fair value of
      its PRC reporting unit substantially exceeds its carrying value. In
providing your response,
      please highlight any significant assumptions used including how the
Company considered
      the previously mentioned negative trends in arriving at its conclusion.
Notes to Consolidated Financial Statements
7. Other Receivables and Current Assets, Net, page F-32

2.    We note you have $390,529 of capitalized merger costs at December 31,
2022. We note
      the SPAC merger was terminated in April 2022. Please clarify for us the
nature of these
      capitalized costs and how you determined it was appropriate to capitalize
such costs at
      December 31, 2022.
18. Income Taxes, page F-51

3.    We note your tax rate reconciliation table on page F-52. Please clarify
for us and in your
      filing the nature of the return-to-provision true-up line item. In
addition, please clarify for
      us your basis in U.S. GAAP for recording this item.
        You may contact Ameen Hamady at 202-551-3891 or Jennifer Monick at
202-551-3295
if you have questions regarding comments on the financial statements and
related
matters. Please contact Ronald Alper at 202-551-3329 or Pam Long at
202-551-3765 with any
other questions.



                                                              Sincerely,
FirstName LastNameDavid Hsu
                                                              Division of
Corporation Finance
Comapany NameSolarMax Technology, Inc.
                                                              Office of Real
Estate & Construction
June 1, 2023 Page 2
cc:       Asher Levitsky
FirstName LastName