December 13, 2005



Mr. Michael J. Anderson
President and Chief Executive Officer
The Andersons, Inc.
480 West Dussel Drive
Maumee, Ohio  43537


	Re:	The Andersons, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2004
Filed March 14, 2005
		File No. 0-20557


Dear Mr. Anderson:

      We have reviewed your Form 10-K for the Fiscal Year Ended
December 31, 2004 and have the following comments.  We have
limited
our review of your filing to those issues we have addressed in our
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 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 information so we may better understand your disclosure.
After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2004

Consolidated Statements of Cash Flows, page 45

1. Please revise your consolidated statements of cash flows to
remove
the subtotal labeled "cash provided by operations before changes
in
operating assets and liabilities".  The presentation of this
amount
is inappropriate as SFAS 95 does not provide for the disclosure of
such balance.

Exhibits 31.1, 31.2 and 31.3

2. In future filings, please revise your certification language in
paragraph 1 to refer to "this report" as opposed to "this annual
report".  The language of the certifications signed by your
officers
should not deviate from the wording in Regulation S-K, Item
601(b)(31).

Form 10-Q for the Quarterly Period Ended March 31, 2005

Financial Information, page 3

Note D, page 9

3. We note your identification of errors in actuarial valuations
used
to assess pension and postretirement benefit obligations and
expenses
during the years 2001 through 2004.  You have disclosed the entire
correction was recorded in the first quarter of 2005, as the
amounts
were not material to the current or prior periods.  Please submit
the
analysis you performed to support your conclusion regarding the
impact of this error correction on the quarterly periods in which
it
relates and the quarterly period in which it was corrected.
Please
ensure your analysis includes an assessment of the impact on
earnings
and earnings per share for each period.  You may refer to SAB
Topic
1:M for further guidance.

4. Tell us how the identification and correction of this error
relating to the calculation of pension and postretirement benefit
obligations and expenses impacted your evaluation of disclosure
controls and procedures as of the current period end as well as
the
prior periods in which the error relates and the evaluation of the
effectiveness of these controls was required.

Form 10-Q/A for the Quarterly Period Ended September 30, 2005

Exhibit 31.3, page 39

5. Please amend your filing to include paragraph 5, part (b) in
the
certification signed by Gary L. Smith.





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
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested 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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a 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 Shannon Buskirk at (202) 551-3717 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3684 with any other
questions.

								Sincerely,



								April M. Sifford
								Branch Chief
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Mr. Anderson
The Andersons, Inc.
December 13, 2005
Page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010