Mail Stop 6010


      October 7, 2005


Via U.S. Mail and Facsimile to (212) 244-0806


Stephen Feldschuh, M.D.
President
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 Quarters Ended March 31, 2005
and
		June 30, 2005
            	File No. 001-09999

Dear Dr. 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 will make no further review 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 as of December 31, 2004

1. Please note that your response to comment 1 is under review by
the
Division of Investment Management.  We may have further comment on
that response once that Division has completed its review.

2. You indicate that you plan to implement several of our
comments,
including comments 3, 6 and 11, effective with the Form 10-Q as of
September 30, 2005.  Please note that we will review your
implementation of those comments once that document is filed.

3. We refer to your response to comment 5. The significant
accounting
policy disclosure is a footnote disclosure required by APB 22.
Critical accounting policy disclosure is an MD&A disclosure
described
in FR-60 and FR-72.  While the footnote disclosure should address
your underlying accounting practices, the critical accounting
policy
disclosure should address the nature and extent of subjective
estimates, management judgment and potential variability inherent
to
the policies you identify as critical.  Accordingly, the
disclosure
objectives are not the same. Please expand future MD&A as
appropriate
to provide critical accounting policy disclosure.

4. We refer to your response to comment 7.  With respect to the
tabular information, please expand future filings to also provide
summary comparative information for the prior year.  Refer to S-K
Item 305(a)(3).

5. We refer to your response to comment 14.  Affirmatively confirm
that you do not have any 10% or more customers about which you
should
make disclosure under paragraph 39 to SFAS 131.  Please note that
the
requirement should be evaluated using total revenues as presented
in
the income statement.  That is, investment income should not be
included in that measure.

6. We refer to your response to comment 15 which indicates that
prior
to June 2005 unrealized gains and losses on short sales of
securities
were not included in income. As set forth in 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" short sales represent obligations to deliver securities,
not
investments and short sale obligations generally are marked to
market, with changes in value recorded in earnings as they occur.

* Please amend the Form 10-K, including the audited financial
statements and the selected financial data schedule included on
page
13, to correctly comply with that guidance. Refer to paragraph 38
of
APB 20.
* Provide us with the amounts of the gross unrealized gains and
gross
unrealized losses relating to your short sales at the end of each
of
the last five fiscal years.
* If you believe that a restatement of your financial statements
is
not required, please provide us with your materiality assessment
of
the amounts and the impact on your reported results of correcting
these accounting errors. Refer to the guidance in SAB 99.

7. With respect to your puts and calls, your responses to comments
15
and 16 indicate that premiums are carried at cost until exercise
or
expiration. Your put and call options on investment securities
appear
to be derivatives under SFAS 133 and under that guidance, you
would
be required to recognize these instruments at fair value and
changes
in fair value would be reflected in earnings.

* Tell us how you have complied with the requirements of SFAS 133
in
accounting for put and call options or explain why that guidance
does
not apply.
* Otherwise, amend the Form 10-K to correctly account for your put
and call options in accordance with SFAS 133.  If you believe that
a
restatement of your financial statements is not required, please
provide us with your materiality assessment of the amounts and the
impact on your reported results of correcting these accounting
errors. Provide us with the amounts of the gross changes in fair
values relating to your put and call options at the end of each of
the last five fiscal years.  Refer to the guidance in SAB 99.

8. We refer to your response to comment 22.  We see that you
appropriately revised the certifications included in the Form 10-Q
for June 30, 2005.  However, we require that all filings include
certifications worded exactly as specified in the regulations.
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.

Form 10-Q as of June 30, 2005

Restatements, page F-7

9. We see that you restated the financial statements in 2005 to
correct an error in the accounting for storage revenues. In a
written
response, show us the impact of the correction on the net loss for
each annual period presented in the 2004 Form 10-K.  As set forth
in
paragraph 38 to APB 20, correction of error accounting is required
when the impact of an error is material to net income or loss for
the
period.  Show us that the amounts involved are not material to net
loss for those periods or otherwise amend the 2004 10-K for this
matter.  If you believe the impact is not material provide us a
SAB
99 analysis.

10. As a related matter, in a written response fully describe how
you
were accounting for advanced storage revenues prior to the
restatement.  Explain how the actual accounting applied differed
from
that as disclosed under "Revenue Recognition" as set forth in Note
1
to the 2004 Form 10-K.

11. In light of the apparent error in your accounting for advanced
storage revenues tell us why you have not filed a Form 8-K
presenting
disclosure under Item 4.02 to that Form.

Other

12. Your response letter dated September 15, 2005 does not include
the written acknowledgement set forth on page 7 to our letter
dated
June 9, 2005.  Your response to this letter must present a written
statement acknowledging the following:

* 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.
*    *    *    *

      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.

      You may contact 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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Dr. Stephen Feldschuh
Daxor Corporation
October 7, 2005
Page 5



Dr. Stephen Feldschuh
Daxor Corporation
October 7, 2005
Page 2