Daxor Corporation

350 Fifth Avenue, Suite 4740

New York, NY 10118

May 20, 2019

Via EDGAR

United States

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re: Daxor Corporation – Post-Effective Amendment No. 4 to

Registration Statement on Form N-2

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the "1933 Act"), the undersigned Registrant  and its principal underwriter, Roth Capital Partners, LLC ("Roth"), hereby request that the above-referenced Post-Effective Amendment No. 4 to the Registration Statement on Form N-2, File No. 333-224509, be declared effective on May 22, 2019, or as soon as is practicable thereafter.  The Registrant and Roth are aware of their obligations under the 1933 Act.

Very truly yours,

ROTH CAPITAL PARTNERS, LLC     By: /s/ Aaron M. Gurewitz   Name: Aaron M. Gurewitz   Title: Head of Equity Capital Markets DAXOR CORPORATION     By: /s/ Robert J. Michel   Name: Robert J. Michel   Title: Chief Financial Officer