April 17, 2006


VIA U.S. MAIL AND FACSIMILE (816) 292-2001

Scott M. Herpich, Esq.
Lathrop & Gage L.C.
2345 Grand Boulevard
Suite 2400
Kansas City, Missouri 64108
(816) 292-2000

Re:	Boston Financial Qualified Housing Tax Credits L.P. III
	Schedule TO-T/A  filed on April 11, 2006,
	by Paco Development, L.L.C.
	File No. 5-81103

Dear Mr. Hepich:

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

Cover Page

1. We note that you have added SLCas, L.L.C. as a filing person to
your schedule TO.  Please amend your Schedule TO to identify this
filing person, explain why you have added such filing person, why
SLCas was not included in the initial filing.  Please amend your
definition of "Purchaser" in your offering materials to include
SLCas.

Units Sought, page 2

2. We note that you have amended your offer to purchase all of the
outstanding units.  Further, we note that your Schedule TO filed
March 10, 2006 addresses the Partnership`s agreement of limited
partnerships prohibiting the transfer of an interest if such
transfer, together with all other transfers during the preceding
12 months, would cause 50% of the total interest in capital and
profits of that partnership to be transferred within such 12-month period.
You state, in that March 10, 2006 filing that you do "not know
whether the general partner will enforce a transfer limitation."
We believe that the general partner has made clear, in both 14D-9
filings of March 17, 2006 and April 14, 2006, that the general
partner will enforce transfer limitations.  Please revise your
disclosure accordingly.  In addition, we believe that you should
detail the pro-ration procedures in the event of
"oversubscription." Further, you should state that you cannot acquire 100%
of the units through the tender offer.

Certain Information Concerning the Participants, page 4

3. We note that  you have filed, together with other participants,
a preliminary proxy filing for a consent solicitation.  We are
unable to locate such filing.  Please advise.

4. Please provide us with your detailed legal analysis of how the
parties you list as participants are related to Paco Development
L.L.C.  and why these parties should not be included as filing
persons on this Schedule TO.  We expect this detailed analysis of
your structure, including these parties, and bidder legal analysis
regardless of the answer to our comment above.

Closing Comment

      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 bidders are in possession of all
facts relating to their 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 bidders acknowledging that:

* the bidders are 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 bidders 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.

      Please amend your filing promptly to comply with our
comments. If you do not agree with a comment, then tell us why in your
response.  If the information you provide in response to our
comments materially changes the information that you have already provided
to unit holders, disseminate the revised materials in a manner
reasonably calculated to inform them of the new information.
Depending upon your response to these comments, a supplement may
need to be sent to unit holders.

      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 direct questions to me at (202) 551-3257.  You may
also contact me via facsimile at (202) 772-9203.  Please send all
correspondence to us at the following ZIP Code:   20549-0303.

							Very truly yours,


							Celeste M. Murphy
							Special Counsel
							Office of Mergers and
							Acquisitions