REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM




Shareholders and Board of Trustees
Churchill Tax-Free Fund of Kentucky
New York, New York


In planning and performing our audit of the financial statements
of the Churchill Tax-Free Fund of Kentucky,  for the year ended
December 31, 2005, in accordance with the standards of the Public
Company Accounting Oversight Board (United States), we considered
its internal control over financial reporting, including control
activities for safeguarding securities, as a basis for designing
our auditing procedures for the purpose of expressing our opinion
on the financial statements and to comply with the requirements of
Form N-SAR, but not for the purpose of expressing an opinion on the
effectiveness of Fund's internal control over financial reporting.
Accordingly, we express no such opinion.

The management of the Fund is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by management
are required to assess the expected benefits and related costs of controls.
company's internal control over financial reporting is a process designed
to provide reasonable assurance regarding the reliability of financial
reporting and the preparation of financial statements for external
purposes in accordance with accounting principles generally accepted
in the United States of America.   Such internal control includes
policies and procedures that provide reasonable assurance regarding
prevention or timely detection of unauthorized acquisition, use or
disposition of a company's assets that could have a material effect
on the financial statements.

Because of inherent limitations, internal control over financial
reporting may not prevent or detect misstatements.   Also, projections
of any evaluation of effectiveness to future periods are subject to
the risk that controls may become inadequate because of changes in
conditions, or that the degree of compliance with the policies or
procedures may deteriorate.

A control deficiency exists when the design or operation of a control
does not allow management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on a timely
basis.   A significant deficiency is a control deficiency, or combination of
control deficiencies, that adversely affects the company's ability to initiate,
authorize, record, process or report financial data reliably in accordance with
accounting principles generally accepted in the United States of America such
that there is more than a remote likelihood that a misstatement of the company's
annual or interim financial statements that is more than inconsequential will
not be prevented or detected. A material weakness is a significant deficiency,
or combination of significant deficiencies, that results in more than a remote
likelihood that a material misstatement of the annual or interim financial
statements will not be prevented or detected.

Our consideration of the Fund's internal control over financial reporting
was for the limited purpose described in the first paragraph and would not
necessarily disclose all deficiencies in internal control that might be
significant deficiencies or material weaknesses under standards established
by the Public Company Accounting Oversight Board (United States).   However,
we noted no deficiencies in Fund's internal control over financial reporting
and its operation, including controls for safeguarding securities, which we
consider to be material weaknesses, as defined above, as of December 31, 2005.

This report is intended solely for the information and use of management,
 Shareholders and Board of Trustees of Churchill Tax-Free Fund of Kentucky
and the Securities and Exchange Commission, and is not intended to be and
should not be used by anyone other than these specified parties.





TAIT, WELLER & BAKER LLP


/s/  TAIT, WELLER & BAKER LLP
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Philadelphia, Pennsylvania
February 16, 2006