MACKEY PRICE THOMPSON & OSTLER
                           A Professional Corporation
                         Attorneys and Counselors at Law

                                American Plaza II
                          57 West 200 South, Suite 350
                          Salt Lake City, UT 84101-3663
                             Telephone 801-575-5000
                                Fax 801-575-5006

Randall A. Mackey
rmackey@mpwlaw.com






                                  June 7, 2005




VIA FEDERAL EXPRESS

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W., Mail Stop 0408
Judiciary Plaza
Washington, D.C. 20549

Attn: Benjamin Phippen
      Staff Accountant

     Re: Security National Financial Corporation  - Amendment No.1 to Form 8-K,
         as filed on May 3, 2005, File No. 000-09341

Ladies and Gentlemen:

     In  connection  with the  above-captioned  Form 8-K (the  "Form  8-K"),  we
enclose  the  following  with  the  Securities  and  Exchange   Commission  (the
"Commission")  for review on behalf of Security National  Financial  Corporation
(the "Company"):





A.   Two conformed copies of Amendment No. 1 (the  "Amendment") to the Form 8-K,
     including exhibits; and

B.   Two additional  conformed  copies of Amendment No. 1 to the Form 8-K, which
     have  been  marked to  indicate  changes  from the Form 8-K filed  with the
     Commission on May 3, 2005.

It should be noted that the Company  electronically  filed the  Amendment to the
Form 8-K via the Edgar system on June 7, 2005.

     We are also  enclosing a copy of the  comment  letter  dated May 31,  2005,
which we received from the staff of the Commission.  The following  responses to
the comments are tied to the numbered paragraphs on the enclosed comment letter.






     1. The Form  8-K has been  revised  to  state  that  Tanner  LC  ("Tanner")
resigned as the  independent  accountants  of the  Company due to the  five-year
partner  rotation  requirement  mandated  by  the  Sarbanes-Oxley  Act  and  the
determination  by Tanner that in the future it would be unable to  maintain  the
necessary   industry   expertise  to  continue  as  the  Company's   independent
accountants.

     2. Because Tanner resigned as the Company's  independent  accountants,  the
Company's  audit  committee  had no choice  but to accept  such  resignation  by
Tanner.  However,  the  Company's  audit  committee  approved the  engagement of
Hansen, Barnett & Maxwell, P.C. ("Hansen") as the new independent accountants to
replace Tanner.

     3. The Company  reported  engagement of Hansen in a Form 8-K that was filed
with the Securities and Exchange  Commission on May 25, 2005. The disclosures in
the May 25, 2005 Form 8-K about  consultations with Hansen were made through the
date of engagement.

     4. In response to this comment,  a letter from Tanner, the Company's former
independent  accountants,  addressing the revised disclosures have been included
as Exhibit 16 to an amended  Form 8-K.  The  amended  Form 8-K,  or Form  8-K/A,
includes the Item 4 designation.

     The Company has  prepared  Amendment  No. 1 to the Form 8-K in an effort to
respond to the comments  from the staff.  Any  additional  comments or questions
should be directed to Randall A. Mackey, Esq, at (801) 575-5000, counsel for the
Company.

                                    Very truly yours,

                                    /s/ Randall A. Mackey
                                    Randall A. Mackey
Enclosures
cc:      Scott M. Quist (w/encls.)
         G. Robert Quist (w/encls.)
         Stephen M. Sill (w/encls.)
         Virgil R. Pugsley (w/encls.)
         Douglas J.  Hansen