March 2, 2005

By Facsimile (432) [682-2560]
Glenn A. Little
Fast Eddie Racing Stables, Inc.
211 West Wall Street
Midland, Texas 79701-4556

Re:  	Fast Eddie Racing Stables, Inc.
	Schedule 14f-1 filed on February 23, 2005
	File No. 005-80568

Dear Mr. Little:

      We have the following comments on the above referenced
filing. 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.

Schedule 14f-1

General

1. It appears that you have concluded that a shareholder vote is
not required in this transaction.  Supplementally advise of the basis
for your belief that Fast Eddie was not required to file a Schedule
14A  or 14C as a result of its transaction with Duncan Capital.

Board and Committee Meetings, page 4

2. We note that that the board of directors does not have any
committees.  In this regard, your future filings should state the
basis for the view of the board of directors that it is
appropriate for the registrant not to have a nominating committee and
identify each director who participates in the consideration of director
nominees.  Also, revise future filings to disclose the information
regarding the director nomination process of Fast Eddie.  See Item
7(d)(2) of Regulation 14A.

3. In future filings, please disclose the information required by
Item 7(f) of Schedule 14A, such as disclosure regarding the number
of meetings of the board of directors.  Also future filings should
disclose whether Fast Eddie has a process for security holders to
send communications to the board of directors, as required by Item
7(h) of Schedule 14A.

Section 16(A) Beneficial Ownership Reporting Compliance, page 5

4. Please revise future filings to identify each officer, director
or beneficial owner of more than ten percent of any class of
securities that is required to file reports under Section 16(a) of the
Exchange Act.  See Item 405 (a)(1) of Regulation S-K.  Also, in light of
the fact that you disclose that certain required filings have not been
made, disclose in your future filings, for each person, the number
of late reports, the number of transactions that were not reported on
a timely basis and any known failure to file a required form.  See
Item 405(a)(2) of Regulation S-K.

Closing Comments

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be certain that they have provided all information investors require
for an informed decision.  Since the issuer is in possession of all
facts relating to its disclosure, it is responsible for the accuracy and
adequacy of the disclosures it has made.

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

* the issuer is responsible for the adequacy and accuracy of the
disclosure in the filings;

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

* the issuer 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.

      As appropriate, please amend your document in response to
these comments.  You may wish to provide us with marked copies of the
amendment, if required, 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 file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your amendment and responses
to our comments.  In addition, depending upon your response to these
comments, a supplement may need to be sent to security holders.


      Please direct any questions to me at (202) 942-1957.  You
may also contact me via facsimile at (202) 942-9638.  Please send all
correspondence to us at the following ZIP code:  20549-0303.

      					Very truly yours,



       					Jeffrey B. Werbitt
						Attorney-Advisor
						Office of Mergers and Acquisitions