Mail Stop 0306


                  June 9, 2005


Via U.S. Mail and Facsimile to (781) 246-3561

Stephen Feldschuh
Vice President of Operations and Principal Accounting Officer
Daxor Corporation
350 Fifth Avenue
Suite 7120
New York, New York 10118


	Re:	Daxor Corporation
		Form 10-K for the Fiscal Year Ended December 31, 2004
		Form 10-Q for the Fiscal Quarter Ended March 31, 2005
      File No. 001-09999

Dear Mr. Feldschuh:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


Form 10-K for the year ended December 31, 2004

General

1. Section 3(a)(1)(C) of the Investment Company Act of 1940
defines
"investment company" as any issuer that "is engaged or proposes to
engage in the business of investing, reinvesting, owning, holding,
or
trading in securities, and owns or proposes to acquire investment
securities having a value exceeding 40 per centum of the value of
such issuer`s total assets (exclusive of Government securities and
cash items) on an unconsolidated basis."  Please provide us with a
written response analyzing whether Daxor is an investment company
under the 1940 Act, including data indicating the value of Daxor`s
investment securities and total assets (exclusive of cash items
and
Government securities) on an unconsolidated basis as of the fiscal
quarters ended June 30, 2004, September 30, 2004, December 31,
2004
and March 31, 2005.  Please also provide appropriate documentation
to
support your analysis.  If you determine that Daxor is an
investment
company:  (1) explain why Daxor is not required to register as an
investment company under the 1940 Act (e.g., provide a complete
and
detailed explanation of the basis for Daxor`s reliance upon any
exemption or exclusion from the definition of investment company
under the 1940 Act); or (2) if no exemption or exclusion from the
definition of investment company is available to Daxor, explain
what
specific remedial action you have taken or plan to take, either to
cause Daxor to fall outside of that definition, or to register
Daxor
as an investment company.

Selected Financial Data
2. In future filings please re-format this table to present the
data
in a manner consistent with that used in your statement of
operations.  For instance, we see that you report dividends,
investment gains and other as non-operating income (as opposed to
revenues) in your income statement.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

3. Please provide some discussion about the components of revenues
for each period.  You should separately quantify and describe
reasons
for changes in revenues from the blood volume, blood banking and
sperm banking businesses.  The disclosure should also separately
address the costs of revenues from each business and should
describe
reasons for changes in gross margins from period to period. Using
the
2004 versus 2003 comparison, show us how you intend to apply this
comment. Apply in future filings.

4. As a related matter, MD&A in future filings should also
identify,
quantify and describe reasons for changes in investment income
(dividends, interest, gains and losses, etc...) from period to
period.

5. In future filings, please revise to provide a discussion of
critical accounting policies.  Refer to FR-60 and FR-72 for
guidance.
Please note that critical accounting policy disclosure should
provide
insight about complex judgments and estimates that underlie the
accounting policies you identify as critical.  Disclosure that
merely
repeats basic accounting policies will not generally satisfy the
objectives of the disclosure.

Liquidity and Capital Resources

6. In future filings please include the tabular disclosure of
contractual obligations required by Item 303 (a)(5) of Regulation
S-
K.  We see, for instance, a lease and other borrowings.

Quantitative and Qualitative Disclosures About Market Risk

7. We see your substantial investment portfolio.  Accordingly, it
appears that you should provide quantitative disclosure about
market
risk as outlined in Item 305 to Regulation S-K.  Show us how you
intend to implement this comment.

8. As a related matter, a put would appear to be a derivative as
defined in SFAS 133.  Unless, insignificant, the expanded
disclosure
should provide appropriate quantitative and qualitative disclosure
about outstanding derivatives.  We also see that you engage in
short
sales.  Please also provide appropriate quantitative and
qualitative
disclosure about those positions.  Refer to Item 305 to Regulation
S-
K for guidance on this disclosure.

Financial Statements

Consolidated Statements of Income

9. In light of your history of losses, the "statements of income"
should be re-titled to "statements of operations" in future
filings.

10. It appears that you provide both services (blood and sperm
banking businesses) and sell products (blood volume business).  In
future filings, please revise the statements of operations to
separately present revenues from product sales and revenues from
services. Correspondingly disaggregate the related costs of sales.
Refer to Rules 5-03 (b) (1) and (2) of Regulation S-X.  If you
believe disaggregated disclosure is not required, show us the
calculations in a supplemental response.

Consolidated Statements of Cash Flows

11. Please disaggregate the item "purchase of marketable
securities,
net" to separately present purchases and sales. Unless the bank
loans
have initial maturities of less than ninety days, that item should
be
similarly disaggregated. Refer to SFAS 95 for guidance.

Statements of Stockholders` Equity and Comprehensive Income

12. Please disclose the amount of income taxes associated with the
adjustment for changes in unrealized gains and losses on
marketable
securities for each income statement period.  Please also disclose
the amount of income taxes associated with the cumulative amount
of
accumulated other comprehensive income as of each balance sheet
date.
Refer to SFAS 130.

Note 1.  Business and Significant Accounting Policies

Segment Information

13. You appear to have three distinct operating businesses in
addition to your investment activities.  Accordingly, it appears
that
you may have as many as four segments. Tell us why you have not
presented segment disclosure under SFAS 131.  If you believe that
this disclosure is not required, you should provide a thorough
analysis of the requirements of that guidance to support your
conclusion.  In connection with this response, identify the chief
operating decision maker and provide us supplemental copies of the
financial reporting package provided that individual (or those
individuals) on a quarterly and annual basis.

14. As a related matter, future filings should also provide
disclosure under paragraphs 37, 38a and 39 to SFAS 131.

Short Sales

15. In Note 6 you make disclosure about short sales indicating
there
are substantial unrealized gains. Tell us how you account for
unrealized gains and losses on short sales.  Question 7 to the
FASB
publication "A Guide to Implementation of Statement 115 on
Accounting
for Certain Investments in Debt and Equity Securities: Questions
and
Answers" indicates that short sales represent obligations to
deliver
securities, not investments and that short sale obligations
generally
are marked to market, with changes in value recorded in earnings
as
they occur.  If that is not your policy, explain the basis in GAAP
for your accounting practices.  Future filings should clarify how
you
account for unrealized gains and losses on short sales.

16. We see from Item 7a that you also sell puts on securities that
you are "willing to own."  In a supplemental narrative, tell us
how
you value and account for these transactions.  That response
should
explain your accounting policies, in detail, and should support
that
those policies are appropriate in GAAP.  Please also make
disclosure
in future filings.

Revenue Recognition

17. Confirm to us that you have not provided guarantees with
respect
to sales financed through the leasing company.  Otherwise, expand
future filings to make disclosure about any guarantees associated
with the leasing arrangements.
Paragraph three of your revenue policy indicates that product
sales
for Volumex and the Blood Volume Analyzer are recognized as
revenue
in the period in which the sale occurs.  Please tell us and revise
future filings to further clarify when you recognize revenue
related
to product sales. For instance is revenue recognized at shipment
or
at delivery?  In a supplemental response, show us that you have
elected an appropriate point for product sales revenue
recognition.
Refer to SAB 104.

18. In that regard, with respect to product sales, tell us about
customer acceptance protocols, if any, and your consideration of
this
matter in determining the timing of revenue.  Similarly address
return policies and practices, and post shipment obligations
(training, upgrades, etc...).  You should provide a supplemental
narrative in response to this comment.  Disclosure in future
filings
should address any significant matters arising from your response.

Note 7.  Stock Options

19. We see that you issued 25,000 options to a consultant with an
exercise price of $21.00.  Future filings should disclose how you
valued and accounted for stock-based compensation granted to non-
employees. You should identify the valuation model and
assumptions;
and, you should disclose the nature of the product or service you
received in return.



Note 8.  Current Income Taxes

20. In future filings expand to make quantified disclosure of the
gross amounts and expiration dates of operating loss and other
carryforwards as required by SFAS 109.  We see that your balance
sheet reports retained earnings.  You should also make some
clarifying disclosure about the origin of the operating losses for
tax purposes.

Item 9A. Controls and Procedures

21. We see that your management evaluated disclosure controls and
procedures as of a date within 90 days of the end of the period.
Please amend to disclose management`s conclusion regarding the
effectiveness of disclosure controls and procedures as of the end
of
the period covered by the annual report.  Refer to Item 307 of
Regulation S-K and Part II.F of Management`s Reports on Internal
Control over Financial Reporting and Certification of Disclosure
in
Exchange Act Periodic Reports, Release No. 33-8238, available on
our
website at www.sec.gov/rules/final/33-8238.htm.

Section 302 Certification - Exhibits 31.1 and 31.2

22. We note that the certifications filed as Exhibits 31.1 and
31.2
were not in the proper form. The required certifications must be
in
the exact form prescribed.  The wording of the required
certifications may not be changed in any respect, except for the
modifications temporarily permitted to be made to the fourth
paragraph of the certification pursuant to Part III.E of Release
No.
8238. Accordingly, please file an amendment to your Form 10-K that
includes the entire filing together with the certifications of
each
of your current CEO and CFO in the form currently set forth in
Item
601(b)(31) of Regulation S-K.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your amendment that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Traci Hornfeck, Staff Accountant, at (202)
551-
3642 or me at (202) 551-3605 if you have questions regarding these
comments.  In this regard, do not hesitate to contact Brian
Cascio,
Branch Chief, at (202) 551-3676.



								Sincerely,



								Gary Todd
								Reviewing Accountant

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Mr. Stephen Feldschuh
Daxor Corporation
June 9, 2005
Page 7



Mr. Stephen Feldschuh
Daxor Corporation
June 9, 2005
Page 2