April 5, 2005


via facsimile and U.S. mail

Mr. William D. Blake
Vice-President and Treasurer
Calcasieu Real Estate & Oil Co., Inc.
One Lakeside Plaza
Lake Charles, Louisiana 70601



	Re:	Calcasieu Real Estate & Oil Co., Inc.
		Form 10-KSB, Filed March 16, 2005
		File No. 001-31905

Dear Mr. Blake:

      We have reviewed the above filing and have the following
comments.  Our review has been limited to the areas commented on
below.  Where indicated, we think you should revise your document
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 filing.
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.

10-KSB for the year ended December 31, 2004

Note 1. Significant Accounting Policies, page 22

1. Please expand your policy disclosure to address the manner in
which you account for your oil and gas royalty interest income and
the associated properties.  Ensure that you indicate whether you
follow the successful efforts or full cost method of accounting
for
the properties in which you own a royalty interest.

2. Add a policy note to address the manner in which you account
for
your timber assets.  Explain the methodology you use to amortize
the
timber as it is sold.

Note 3. Oil and Gas Properties, page 26

3. We note your statement "Reserve information relating to
estimated
quantities of the Company`s interest in proved reserves of natural
gas and crude (including condensate and natural gas liquids) is
not
available."  Confirm, if true, that you are relying upon the
exception in paragraph 10 of SFAS 69 for royalty interests owned
as
your basis for not presenting proved oil and gas reserve
quantities
as required by paragraph 7(a).  Please note that if you are
relying
upon this exception, you are required, as stated in paragraph 10,
to
disclose "the enterprise`s share of oil and gas produced for those
royalty interests ... for the year."  In addition, this exception
should not preclude disclosure of the additional supplementary
information required by paragraphs 7(b) - (e).  Tell us why you
have
not provided all of the supplementary disclosures required by SFAS
69, given that your royalty revenues, which are included in the
definition of revenues in paragraph 25, represent 10% or more of
the
combined revenues of all of your industry segments.

Note 6. Company Operations, page 28

4. We note your disclosure on page 2, stating that you do not
report
financial information by segments "...because neither agriculture
nor
timber produce as much as 15% of total receipts."  Please submit
the
quantitative threshold tests that you performed for each period
under
paragraphs 18(a) and (c) of SFAS 131, in determining that
additional
segment information is not required.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
amendment to expedite our review.  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 understand that we may have
additional comments after reviewing your amendment and 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 the 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 Jennifer Goeken at (202) 824-5287, or in her
absence, Karl Hiller at (202) 942-1981, if you have questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 942-1870 with any other questions.
Direct
all correspondence to the following ZIP code:  20549-0405.

							Sincerely,



							H. Roger Schwall
							Assistant Director


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Calcasieu Real Estate & Oil Co., Inc.
April 5, 2005
page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE