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                          March 15, 2021

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

                                                        Re: IMAC Holdings, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed March 11,
2021
                                                            File No. 333-254183

       Dear Mr. Ervin:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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 David
Gessert at 202-551-2326 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences