May 6, 2019

Jeff Kaminski
Chief Financial Officer
KB Home
10990 Wilshire Boulevard
Los Angeles, CA 90024

       Re: KB Home
           Form 10-K for the Fiscal Year Ended November 30, 2018
           Filed January 24, 2019
           Form 10-Q for the Fiscal Quarter Ended February 28, 2019
           Filed April 5, 2019
           File No. 001-09195

Dear Mr. Kaminski:

       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-Q for the Fiscal Quarter Ended February 28, 2019

Financial Statements
1. Basis of Presentation and Significant Accounting Policies
Adoption of New Accounting Pronouncement, page 6

1.     We note your disclosure that the costs of sales incentives in the form
of free or discounted
       products or services to homebuyers, including option upgrades and
closing cost
       allowances used to cover a portion of the fees and costs charged to a
homebuyer, are
       reflected as construction and land costs. Please tell us how you
considered the guidance
       in ASC 606-10-32-25 through 27 in your determination that these sales
incentives should
       be reflected as costs rather than as a reduction of the transaction
price. Please address this
       comment as it relates to each type of incentive and identify the
distinct good or service a
       customer transfers to you.
 Jeff Kaminski
KB Home
May 6, 2019
Page 2
2.       We note your disclosure: "In instances where we have a material
performance
         obligation(s) under a land sale contract to perform land development
work after the
         closing date, a portion of the transaction price is allocated to such
performance
         obligation(s) and is recognized as revenue when and as such
obligation(s) is (are)
         completed. While the payment terms for such a performance
obligation(s) vary, the final
         payment is generally received when we have completed our land
development work and it
         has been accepted by the land buyer." Please address the following:
           Explain the nature of the land development work and describe your
analysis under
             ASC 606-10-25-19 in determining that the land and the land
development work are
             distinct; and
           Explain the nature of the acceptance provisions of the land
development work by land
             buyers and describe your analysis under ASC 606-10-25-30 and ASC
606-10-55-85
             through ASC 606-10-55-88 in determining that recognizing revenue
for the land sale
             prior to buyer acceptance is appropriate.
3.       We note you disclose customer deposits as of each balance sheet date.
Please tell us how
         you considered ASC 606-10-50-8b, which requires disclosure of the
amount of revenue
         recognized during the period that was included in customer deposits as
of the beginning of
         the period.
       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 Anne McConnell at
202-551-3709
with any questions.



                                                             Sincerely,
FirstName LastNameJeff Kaminski
                                                             Division of
Corporation Finance
Comapany NameKB Home
                                                             Office of
Manufacturing and
May 6, 2019 Page 2                                           Construction
FirstName LastName