September 17, 2018

Gary Smalley
Chief Financial Officer
TUTOR PERINI CORP
15901 Olden Street
Sylmar, CA 91342-1093

       Re: TUTOR PERINI CORP
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 27, 2018
           File No. 001-06314

Dear Mr. Smalley:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Specialty Contractors Segment, page 23

1.    Your disclosure states that "income from construction operations
decreased 50% in 2017
      compared to 2016, principally due to the impact of unfavorable project
adjustments on
      certain mechanical projects in New York and California, none of which
were individually
      material." To the extent that the unfavorable project adjustments were
material in the
      aggregate, please revise future filings to also quantify the total of
such adjustments. Please
      refer to Item 303(A)(3)(i) of Regulation S-K for guidance.
Critical Accounting Policies   Recoverability of Goodwill, page 28

2.    We note that your market capitalization is significantly below your
equity value at both
 Gary Smalley
TUTOR PERINI CORP
September 17, 2018
Page 2
         December 31, 2017 and June 30, 2018. Please explain to us how you have
considered this
         significant difference in your goodwill impairment analysis as of
December 31, 2017.
         Additionally, please tell us if you have performed an interim
impairment analysis
         subsequent to December 31, 2017, and if so, please tell us the results
of such analysis.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Dale Welcome at 202-551-3865 or John Cash at
202-551-3768 with
any questions.



                                                            Sincerely,
FirstName LastNameGary Smalley
                                                            Division of
Corporation Finance
Comapany NameTUTOR PERINI CORP
                                                            Office of
Manufacturing and
September 17, 2018 Page 2                                   Construction
FirstName LastName