May 26, 2005

Via Facsimile ((561) 392-8311) and U.S. Mail

Leonard S. Mandor
c/o Concord Milestone Plus, L.P.
200 Congress Park Drive, Suite 103
Delray Beach, FL  33445

RE:	Concord Milestone Plus, L.P.
      Amended Schedule 14D-9 filed May 19, 2005
      File No. 005-40562

Ladies and Gentlemen:

      We have the following comments on the above-referenced
filing.

Schedule 14D-9

The Solicitation or Recommendation - Page 2

1. We reissue comment 1.  We are unable to find a description of
the reasons for your lack of recommendation to explain why the
partnership is indifferent as to who owns the interests in the
partnership.

2. We note your response to comment 2 and the supplemental
materials provided to us.  Please provide us your analysis of whether
disclosure of the terms of the bid received is required under Item
8 of Schedule 14D-9.

Closing Information

      Please amend your filing promptly to comply with our
comments. If you do not agree with a comment, please tell us why in
your response.  If the information you provide in response to our
comments materially changes the information that you have already
provided to security holders, disseminate the revised materials in
a manner reasonably calculated to inform them of the new information.


      Please direct any questions to me at (202) 551-3619 or, in
my absence, to Nicholas Panos, Special Counsel, at (202) 551-3266.
You may also contact me via facsimile at (202) 772-9203.  Please send
all correspondence to us at the following ZIP code: 20549-0303.


								Sincerely,



								Daniel F. Duchovny
								Attorney-Advisor
								Office of Mergers &
								Acquisitions