January 2, 2020

Pei Xu
Chief Financial Officer
Zhongchao Inc.
Nanxi Creative Center, Suite 218
841 Yan' An Middle Road
Jing' An District
Shanghai, China 200040

       Re: Zhongchao Inc.
           Registration Statement on Form F-1/A
           Filed December 27, 2019
           File No. 333-234807

Dear Ms. Xu:

        We have reviewed your amended registration statement and have the
following
comment. Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe our comment applies 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 this comment, we may have additional comments.

Form F-1/A Filed December 27, 2019

Consolidated Financial Statements, page F-1

1.     It appears that the last year of audited financial statements will be
older than 12 months at
       the time of the offering. Furthermore, it appears this is the initial
public offering of your
       shares. Accordingly, please update the last year of audited financial
statements pursuant
       to Item 8.A.4 of Form 20-F or provide the appropriate representation in
an exhibit.
       Please refer to Instruction 2 to Item 8.A.4.



       You may contact Christie Wong, Staff Accountant, at 202-551-3684, or
Lisa Etheredge,
Staff Accountant, at 202-551-3424, if you have questions regarding comments on
the financial
statements and related matters. Please contact Paul Fischer, Staff Attorney, at
202-551-3415, or
 Pei Xu
Zhongchao Inc.
January 2, 2020
Page 2

Celeste M. Murphy, Legal Branch Chief, at 202-551-3257, with any other
questions.



                                                         Sincerely,
FirstName LastNamePei Xu
                                                         Division of
Corporation Finance
Comapany NameZhongchao Inc.
                                                         Office of Trade &
Services
January 2, 2020 Page 2
cc:       Arila Zhou, Esq.
FirstName LastName