May 12, 2005
Mail Stop 0305

Via U.S. Mail and Facsimile

Larry J. Goddard
Chief Financial Officer
P.A.M. Transportation Services, Inc.
297 West Henri De Tonti Blvd
P.O. Box 188
Tontitown, Arkansas 72770-0188

RE:	P.A.M. Transportation Services, Inc. (the "Company")
	Form 10-K for the fiscal year ended December 31, 2004
	File No. 0-15057
	Schedule 14A Proxy Statement filed on April 21, 2005
	File No. 0-15057


Dear Mr. Goddard:


We have reviewed your response letter dated April 27, 2005 and
have
the following comments.  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 comments are not
applicable or a revision is unnecessary.  We also ask you to
provide
us with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary.  We look forward
to
working with you in these respects and welcome any questions you
may
have about any aspects of our review.

Please respond to confirm that the comment will be complied with,
or,
if the comment is deemed inappropriate by the Company, advise the
staff of the reason thereof.  Pursuant to Rule 101(a)(3) of
Regulation S-T, your response should be submitted in electronic
form,
under the label "corresp" with a copy to the staff.  Please
respond
within ten (10) business days.



Form 10-K for the fiscal year ended December 31, 2004

Note 1 - Accounting Policies
- Revenue Recognition, page 36

1. We note your response to our prior comment number three.
Please
clarify your revenue recognition policy in future filings to
specifically state that expenses related to freight in transit at
the
end of a reporting period are recognized as incurred.

Note 18 - Acquisitions, page 50

2. We note your response to prior comment number six and the
reasons
why you believe that intangible assets which require recognition
apart from goodwill did not exist at the time of acquisition.
Reference is made your response regarding customer base.  We note
that you determined that the customer base acquired in connection
with the acquisition of East Coast Transport, Inc. did not meet
the
criteria for recognition apart from goodwill based upon the
guidance
outlined in paragraph B165 of SFAS No. 141, which is also premised
on
the view that a customer base is a group of customers that are not
known or identifiable to the entity (such as customers of a fast-
food
franchise).  We note although the customers are not bound by
contracts, each customer order is negotiated individually which
appears to indicate that the nature of the business requires the
customer to be known and identifiable.  This is further supported
by
the fact that you also acquired a customer list as part of the
acquisition.  In this regard, please tell us how you considered
these
factors in determining whether customer-related intangible assets
(i.e.  noncontractual customer relationships) separate from
goodwill
existed at the time of acquisition.  We may have further comment
upon
receipt of your response.

3. We note your response regarding brokerage agents.  Please
supplementally explain in further detail why you believe your
agent
relationships represent workforce in place.  Tell us the relevant
guidance which supports your position.  Further, you disclose that
due to the open nature of the agreements which allow for
termination
without penalty or indefinite extension made the estimation of a
useful life extremely uncertain.  However, paragraph B174 of SFAS
No.
141 states that a present value technique might often be the best
available technique to estimate the fair value of an acquired
intangible asset, and such technique requires judgment in
estimating
the period and amount of expected cash flows which incorporates
assumptions such as future contract renewals and other benefits
that
might result in acquisition related synergies.  It also states
that
past history often provides evidence that the contracts or rights
are
generally renewed without substantial cost and effort.  Tell us
how
you considered paragraph B174 of SFAS No.141 in determining
whether
an intangible asset separate from goodwill should be recognized
for
contracts with such brokerage agents.  We may have further comment
upon receipt of your response.

Schedule 14A Proxy Statement
Compensation Committee Interlocks and Insider Participation

4. The discussion on page 7 of your Schedule 14A Proxy Statement
regarding transactions with certain entities affiliated with your
executive officers is inconsistent with that provided in Note 7 to
your audited financial statements. In future filings, please
reconcile and revise these disclosures.

* * * * * * * *

You may contact Jean Yu at (202) 551-3305 or Linda Cvrkel, Branch
Chief at (202) 551-3813 if you have questions regarding comments
on
the financial statements and related matters.

								Sincerely,


								Linda Cvrkel
								Branch Chief

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Larry J. Goddard
P.A.M. Transportation Services, Inc.
May 12, 2005
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