Subject: File No. S7-26-97

     
                                    The Andersons, Inc.
                                    P.O. Box 119
                                    480 W. Dussel Drive
                                    Maumee, Ohio 43537
                                    Phone: (419) 893-5050
                                    November 12, 1997
     
        Jonathan G. Katz, Secretary
        U.S. Securities and Exchange Commission 
        450 Fifth Street, N.W.
        Washington, D.C.  20549
     
        Dear Mr. Katz:
     
           The Andersons. Inc. of Maumee, Ohio (NASDAQ listed as "ANDE") is
        a diversified agricultural, manufacturing and retail company with 
        facilities located in Ohio, Indiana, Michigan and Illinois. 
        Celebrating our 50th Anniversary, we are proud of a lon tradition 
        of charitable and community involvement and support.
     
           As we have mentioned directly to the sponsor of H.R. 944 and
        945, Congressman Paul Gillmor, we have some serious misgivings 
        about the content and potential impact of these two pieces of 
        legislation.  Congressman Gillmor has urged us to respond to your 
        office with our concerns.
     
           You have posed three questions about the 1) feasibility, 2)
        costs, and 3) benefits of each proposal.
     
           As to H.R. 944:
     
        1)  Feasibility - While we view this potential requirement for 
        additional regulatory reporting of questionable value to 
        shareholders and corporations, it would be technically possible to 
        report all direct charitable giving.  We suggest, at most, the 
        reporting of total charitable giving with advice about how an 
        interested shareholder would obtain more information as desired.
     
        2)  Cost - This proposal is seen as another incremental cost of 
        compliance which will be added to the existing load of government 
        reporting, a load which is seldom reduced, but often increased.
     
        3)  Benefits - The cost/benefit relationship of this proposal is 
        very poor.  Given the many corporate decisions appropriately 
        delegated by ownership to its management, it is difficult to 
        justify detailed reporting on this particular item.
     
     
        Mr. Katz
        November 12, 1997
     
        Page  2
     
        As to H.R. 945:
     
        Note:  As to H.R. 945, we view this bill as quite confusing and, in 
        part, contradictory as drafted.  We make these remarks in that 
        light.
     
        1)  Feasibility - We must strenuously caution against any such 
        requirement that corporate giving practices be replaced with 
        shareholder-by-shareholder designations.  The time, complexity, 
        expense and random nature of such a program would drastically 
        interfere with a quite remarkable system of public and private 
        review and support of countless worthy causes.  How could a charity 
        predict and plan the source of support for a worthwhile project? 
        What criteria would the shareholders apply, if any, in making 
        thousands of isolated decisions?
     
        2)  Costs - It goes without saying that the proxy procedure is 
        complicated and costly and would serve as a major disincentive to 
        conducting such process to meet charitable requests in a timely 
        manner.  It just wouldn't be worth the effort to shareholders or 
        their corporations.
     
        3)  Benefits - Shareholders elect a board of directors who appoint 
        and review a group of officers who are assigned a myriad of 
        responsibilities on behalf of their corporate ownership.  Of 
        course, shareholders have "rights" but imposing additional 
        government restrictions on corporate management will not be in the 
        shareholders' ultimate best interest.  Community and charitable 
        service and support is a corporate duty and opportunity that 
        requires and deserves management's full attention and resources as 
        are applied to other important corporate obligations.  This 
        proposal would seriously interfere with this important work and 
        greatly diminish the power of collective giving by diluting already 
        limited funds.
     
           Basically, we believe both bills are ill advised.  We trust
        Congressman Gillmor and his colleagues will take these inputs into 
        consideration and balance all the interests involved in a 
        thoughtful and constructive manner.
     
                                     Sincerely,
     
                                     /s/Michael J. Anderson
     
                                     Michael J. Anderson
                                     President and COO
     
        MJA:DWF:bjl
        cc:        The Honorable Paul E. Gillmor
                   The Honorable Michael G. Oxley