UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE



							April 20, 2005


via facsimile and U.S. mail
Mr. Michael C. Coffman
Chief Financial Officer
Grand Centre, Suite 305
5400 North Grand Blvd.
Oklahoma City, OK 73112



	Re:	Panhandle Royalty Company
		Form 10-K for the year ended September 30, 2004
		Form 10-Q for the period ending December 31, 2004
		Response letter dated April 14, 2005
		File No. 1-9210


Dear Mr. Coffman:

      We have reviewed the above filings and response letter and
have
the following comments. Our review has been limited to your
financial
statements, Management`s Discussion and Analysis, and certain
property information.  Where indicated, we think you should revise
your documents in response to these comments.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or revision is unnecessary.  Please be as detailed as necessary in
your explanation.

      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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



10-K for the year ended September 30, 2004

Financial Statements

      Note 1- Summary of Significant Accounting Policies, page 28

1.	We note in your response to prior comment 1 that you have
concluded that perpetual fee minerals, included in non-producing
oil
and gas properties, meet the criteria of pg. 28 of SFAS 19 for
aggregation and amortization, as you own a large number of
individually insignificant properties. In future filings, please
expand your disclosure to indicate the period that these
properties
are being amortized, the method used to amortize them, how they
are
grouped and, finally, how you determined the amortization period.


Closing Comments

      As appropriate, please amend your filing(s) 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 amendment(s) to expedite our review.  Please furnish a
cover letter with your amendment(s) that keys your responses to
our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment(s) and responses to our comments.

      Direct questions regarding accounting issues and related
disclosures to Tracie Towner at (202) 824-5673, or in her absence,
to
Jill Davis, Branch Chief Accountant, at (202) 942-1986.  Direct
questions relating to all other disclosure issues to the
undersigned
at (202) 942-1870.


							Sincerely,



							H. Roger Schwall
							Assistant Director
Panhandle Royalty Company
April 20, 2005
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