April 11, 2019

Martin Connor
Chief Financial Officer
TOLL BROTHERS INC
250 Gibraltar Road
Horsham, Pennsylvania 19044

       Re: TOLL BROTHERS INC
           Form 10-K for the period ended October 31, 2018
           Filed on December 20, 2018
           Form 10-Q for the period ended January 31, 2019
           Filed on March 8, 2019
           File No. 001-09186

Dear Mr. Connor:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the period ended October 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 32

1.    We note your discussion and analysis of income taxes on page 33.
Referring to the "other"
      caption in your effective tax rate reconciliation in Note 8, please
explain the specific facts
      and circumstances that resulted in an $11.5 million benefit to the
provision in 2018 and an
      $8.6 million expense in the prior year. Given these amounts had a
material impact to your
      income tax provision for the year, your discussion should describe the
material factors
      within this line item that drove the change between the periods
presented, whether they
      are recurring, and the potential impact on future operations. Please
refer to Item 303(a)(3)
      of Regulation S-K and Section 501.12 of the Financial Reporting
Codification for
      guidance.
 Martin Connor
TOLL BROTHERS INC
April 11, 2019
Page 2
Form 10-Q for the period ended January 31, 2019

Significant Accounting Policies
Revenue Recognition, page 6

2.       We note that in certain states you are not able to complete certain
outdoor features prior to
         the closing of the home. To the extent these separate performance
obligations are not
         complete prior to delivering the home, you defer a portion of the home
sales revenues
         related to these separate performance obligations. Please tell us the
nature of the outdoor
         features and describe your analysis under ASC 606-10-25-19.
3.       We note your disclosure that effective November 1, 2018, in land
transactions that contain
         repurchase options, revenues and related costs are not recognized
until the repurchase
         option expires. It does not appear that your policy addresses the
accounting for the
         contract as either a lease or financing arrangement. Please tell us
your consideration of
         ASC 606-10-55-66 through 78 in your accounting for these transactions.
4.       According to your disclosure, you treat incentives such as payment of
a home buyer's
         closing costs as additional costs of sales when paid to a third party.
Please tell us how you
         considered the guidance in ASC 606-10-32-25 through 27 in your
determination that the
         costs paid to third parties, such as home buyer closing costs, should
be reflected as
         expense rather than as a reduction of transaction price.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

      You may contact Ameen Hamady at 202-551-3891 or in his absence Terence O'
Brien at
202-551-3355 with any questions.



                                                                Sincerely,
FirstName LastNameMartin Connor
                                                                Division of
Corporation Finance
Comapany NameTOLL BROTHERS INC
                                                                Office of
Manufacturing and
April 11, 2019 Page 2                                           Construction
FirstName LastName