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                       December 23, 2020

       Brandon E. Lacoff
       Chairman and Chief Executive Officer
       Belpointe REIT, Inc.
       125 Greenwich Avenue, 3rd Floor
       Greenwich, CT 06830

                                                        Re: Belpointe REIT,
Inc.
                                                            Offering Statement
on Form 1-A
                                                            Post-Qualification
Amendment No. 9
                                                            Filed December 16,
2020
                                                            File No. 024-10923

       Dear Mr. Lacoff:

                                                        We have reviewed your
amendment and do not have any comments.

               We will consider qualifying your offering statement at your
request. If a participant in
       your offering is required to clear its compensation arrangements with
FINRA, please have
       FINRA advise us that it has no objections to the compensation
arrangements prior to
       qualification.

               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 Ronald (Ron) E. Alper at 202-551-3329 or Erin E.
Martin at 202-551-3391
       with any questions.




                       Sincerely,


                       Division of Corporation Finance

                       Office of Real Estate & Construction
       cc:                                              Vanessa Schoenthaler