October 22, 2019

John Albright
President and Chief Executive Officer
Alpine Income Property Trust, Inc.
1140 N. Williamson Blvd., Suite 140
Daytona Beach, Florida 32114

       Re: Alpine Income Property Trust, Inc.
           Draft Registration Statement on Form S-11
           Amendment Submitted October 3, 2019
           CIK No. 0001786117

Dear Mr. Albright:

      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 September
23, 2019 letter.



DRS/A Form S-11 filed October 3, 2019

Acquisitions Under Evaluation, page 5

1.     We note your response to comment 9 and your revised disclosure on page 6
regarding
       properties under contract. Please provide us a brief description of the
properties under
       contract and explain to us how you determined that the acquisitions of
these properties
       under contract are not probable.
 John Albright
FirstName LastNameJohn Albright
Alpine Income Property Trust, Inc.
Comapany NameAlpine Income Property Trust, Inc.
October 22, 2019
Page 2
October 22, 2019 Page 2
FirstName LastName



2.       We reissue comment 10. We note your disclosure on page 5 that "CTO is
currently
         reviewing acquisition opportunities of single-tenant, net leased
properties from third-
         parties . . . ." Please describe in the prospectus your criteria for
determining when you
         include a property in your pipeline or properties under evaluation,
explain how you have
         identified such properties, clarify whether you have any relationship
with the sellers,
         including whether or not there is some type of contractual obligation,
such as a right of
         first offer, and discuss the impact of timing and due diligence.
Our Manager and the Management Agreement, page 128

3.       We note your disclosure on page 135 that you will not reimburse any
compensation
         expenses incurred by your manager and your revised disclosure on page
158 that your
         operating partnership will pay all of your administrative costs and
expenses, including
         salaries and other payments to directors, officers or employees of you
and the general
         partners as well as all costs and expenses associated with any health,
dental, vision,
         disability, life insurance, 401(k) plan, incentive plan, bonus plan or
other plan providing
         compensation. Please clarify whose salaries and what other payments
are to be paid by
         the operating partnership and, as applicable, provide disclosure
required by Items 402 and
         404 of Regulation S-K.
Formation Transactions, page F-2

4.       We have considered your response to our prior comment 15. Based on
your response, it
         appears you have concluded that the company is acquiring a set of
similar assets. Your
         disclosure on page 5 indicates you will be acquiring a portfolio of
retail and office
         properties. Please explain to us how you determined retail and office
properties have
         similar risk characteristics such that they can be considered similar
assets. In your
         response, tell us how you considered the risks associated with
operating the assets,
         obtaining tenants and tenant management; how those risks are similar
between office and
         retail properties and how they are different. Reference is made to ASC
Topic 805-10-55-
         6. Additionally, in your response you indicate that all of your
properties are subject to
         triple-net leases. Please reconcile this statement with disclosure on
page 1, and elsewhere
         in your filing, which states that properties in your initial portfolio
are primarily subject to
         triple-net leases.
5.       We note in your response to our prior comment 15 that you do not
believe you will
         acquire a substantive process as a result of the acquisition of the
initial portfolio, but
         rather you will enter into a new contract for management services.
Please clarify for us
         whether the management agreement was entered into in contemplation of
the acquisition
         transaction, and if so, elaborate on why you do not believe entering
into the agreement
         represents the acquisition of a substantive process.
 John Albright
Alpine Income Property Trust, Inc.
October 22, 2019
Page 3


       You may contact Peter McPhun at 202-551-3581 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Pam Howell at 202-551-3357 or Jennifer Gowetski at 202-551-3401 with
any other
questions.



FirstName LastNameJohn Albright                           Sincerely,
Comapany NameAlpine Income Property Trust, Inc.
                                                          Division of
Corporation Finance
October 22, 2019 Page 3                                   Office of Real Estate
& Construction
FirstName LastName