November 12, 2004


VIA EDGAR (Correspondence Filing)

Ms. Patsy Mengiste
Securities and Exchange Commission
450 Fifth Street, N.W.
(Mail Stop 05-05)
Washington, D.C. 20549-5005


ATTN:   Document Control - EDGAR


RE:     AXP Stock Series, Inc.
                 AXP Stock Fund
                 Post-Effective Amendment No. 106 ("Amendment No. 106")
                 File Nos. 2-11358 / 811-498

Dear Ms. Mengiste:

This letter is in response to Staff's oral comments that you communicated to us
by telephone on or about November 10, 2004 for the fund referenced above.

                                   PROSPECTUS

COMMENT 1: Page 3p. With respect to the 80% rule, please clarify if "commercial
paper" in the following sentence falls under the 80% rule or outside of the 80%
rule.

"The Fund's assets primarily are invested in common stocks and securities
convertible into common stocks. Under normal market conditions, at least 80% of
the Fund's net assets are invested in these securities. In pursuit of its income
objective, the Fund will invest in income-producing equity securities (such as
convertible securities and preferred stocks) and short-term debt instruments
(such as commercial paper)."

RESPONSE: Commercial paper investments are not counted under the 80% rule. The
above-referenced sentence be revised as follows:

"The Fund's assets primarily are invested in common stocks and securities
convertible into common stocks. Under normal market conditions, at least 80% of
the Fund's net assets are invested in these securities. The Fund will provide
shareholders with at least 60 days' notice of any change in the 80% policy.

In order to provide current income to shareholders, the Fund may invest in
income-producing equity securities (such as convertible securities and preferred
stocks) and short-term debt instruments (such as commercial paper)."



COMMENT 2: Pages 8 and 9. With  respect to the  descriptions of Dimitris J.
Bertsimas, Gina K. Mourtzinou  and  Scott  Mullinix,  please clarify  in what
capacity they joined American Express Financial Corporation. In addition, please
state in what capacity  they were  employed at their  previous firms. Lastly,
please state what kind of business is "Dynamic Ideas, LLC."

RESPONSE: Upon amendment, Registrant will revise the portfolio manager sections
to reflect the above-referenced comments.

COMMENT 3: With respect to market timing language, you may not use the same
language for "international/emerging markets" type funds.

RESPONSE: Registrant will have a domestic version and an international/emerging
markets version of the market timing language. The domestic language reviewed in
this filing will be template language for all funds except
international/emerging markets funds. Per your instructions, Registrant will be
sending additional correspondence requesting approval of subsequent filings with
this language pursuant to Rule 485(b)(1)(vii).

Staff had no additional comments except the requirement to make the following
representation on behalf of the Registrant:

In connection with Amendment No. 106, the Registrant,  hereby  acknowledges  the
following:

         The disclosures in the filing are the responsibility of the Registrant
         and the Registrant is fully responsible for the adequacy or accuracy of
         the disclosures in this filing. The Registrant represents to the
         Commission that comments made by the Commission, or the staff acting
         pursuant to delegated authority, or changes to disclosure in response
         to staff comments in the filing reviewed by the staff, do not foreclose
         the Commission from taking any action with respect to the filing, and
         the Registrant represents that it will not assert this action as a
         defense in any proceeding initiated by the Commission or any person,
         under the federal securities laws of the United States.

In addition to selective review of Amendment No. 106,  Registrant also requested
acceleration of Amendment No.106 to November 15, 2004.  Registrant would like to
move  this  acceleration  date  to  November  29,  2004.  Upon  filing  of  this
correspondence, it is our understanding that you agreed to grant acceleration of
Amendment No. 106 as of November 29, 2004.  Please note that Registrant  intends
to go effective  with a subsequent  Post-Effective  Amendment  filing under Rule
485(b) on or about November 29, 2004.

If you have any questions, please contact Christopher O. Petersen at (612) 671-
4321 or Simone Pepper at (612) 671-2847.


Sincerely,


/s/ Leslie L. Ogg
    ----------------
    Leslie L. Ogg
    Vice President, General Counsel and Secretary