February 14, 2006


Mail Stop 4561



VIA U.S. MAIL AND FAX (301)468-3180

H. William Willoughby
Director, President and Secretary
Capital Realty Investors II, LTD Partnership
11200 Rockville Pike
Rockville, Maryland 20852

Re:	Capital Realty Investors II, LTD Partnership
	File No. 000-11973
      Form 10-K for Fiscal Year Ended
	December 31, 2004
	Form 10-Q for Quarterly Periods Ended
	March 31, 2005, June 30, 2005 & September 30, 2005

Dear Mr. Willoughby:

      We have reviewed your response letter dated January 9, 2006
and
have the following additional comment.  If you disagree with our
comment, we will consider your explanation as to why our comment
is
not applicable.  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.

Exhibit 99 Reports of Other Auditors

1. We have considered your response to our prior comment.  Please
confirm for us that you will insure that ALL accounting reports
filed
as exhibits to future filings make reference to the PCAOB
standards.
All of the other auditors` reports that the principal auditor
chooses
to place reliance on must refer to the "PCAOB Standards",
regardless
of whether they met the threshold of being required to be
registered
with the PCAOB.


      Please respond to the comments included in this letter
within
ten business days.  Please file your response on EDGAR.  If you
have
any questions, you may contact Robert Telewicz at (202) 551-3438
or
me at (202) 551-3414.

								Sincerely,



      Jorge L. Bonilla
      Senior Staff Accountant

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H. William Willoughby
Capital Realty Investors II, LTD.
February 14, 2006
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