August 8, 2019

Jeffrey S. Ervin
Chief Executive Officer
IMAC Holdings, Inc.
1605 Westgate Circle
Brentwood, Tennessee 37027

       Re: IMAC Holdings, Inc.
           Registration Statement on Form S-1
           Filed July 25, 2019
           File No. 333-232820

Dear Mr. Ervin:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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.

Form S-1 filed July 25, 2019

Choice of Forum, page 37

1.     With respect to the exclusive forum provision in your certificate of
incorporation, we note
       your disclosure allowing for a carve-out for matters in which no Court
of Chancery in the
       state of Delaware has jurisdiction. However, we find no such carve-out
provision in the
       certificate of incorporation which you have incorporated by reference
into your filing.
       Please advise.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
 Jeffrey S. Ervin
IMAC Holdings, Inc.
August 8, 2019
Page 2

time for us to review any amendment prior to the requested effective date of
the registration
statement.

      You may contact Gregory Dundas, Attorney-Adviser, at (202) 551-3436 or
Celeste
Murphy, Legal Branch Chief, at (202) 551-3258 with any questions.



                                                             Sincerely,
FirstName LastNameJeffrey S. Ervin
                                                             Division of
Corporation Finance
Comapany NameIMAC Holdings, Inc.
                                                             Office of
Telecommunications
August 8, 2019 Page 2
cc:       Spencer G. Feldman
FirstName LastName