July 31, 2007

United States Securities and Exchange Commission

Washington, D. C. 20549

Attn: Mr. Kevin Woody

Branch Chief

Re: Kimco Realty Corporation (the “Company”)

Form 10-K for the year ended December 31, 2006

Form 10-Q for the quarterly period ended March 31, 2007

File No. 1-10899

Dear Mr. Woody:

In reply to your letter dated July 23, 2007, on the above-mentioned File Number, please find our responses to your comments:

Form 10-K for the year ended December 31, 2006

Financial Statements

Consolidated Statements of Income, page 72

1. We have reviewed your response to our prior comment number one. Please tell us management’s basis for determining that the line item revenues from rental property less rental property expenses does not violate Item 10(e)(1)(ii)(C).

Response

The Company has further reviewed the provisions of Item 10(e)(1)(ii)(C) of Regulation S-K and has removed the line item revenues from rental property less rental property expenses. In future filings, the Company will present its Consolidated Statements of Income as follows (in thousands):

	Year Ended December 31, 2006
Revenues from rental property	$ 593,880
Rental property expenses:
Rent	(11,786)
Real estate taxes	(75,515)
Operating and maintenance	(74,178)
Mortgage and other financing income	18,816
Management and other fee income	40,684
Depreciation and amortization	(141,070)
General and administrative expenses	(77,683)
Interest, dividends and other investment income	54,417
Other income, net	9,522
Interest expense	(172,888)
Income from continuing operations before income taxes, Income from other real estate investments, Equity in income of real estate joint ventures, Minority interests in income, and Gain on sale of development properties	164,199
Provision for income taxes	(4,387)
Income from other real estate investments	77,062
Equity in income of real estate joint ventures, net	106,930
Minority interests in income, net	(26,254)
Gain on sale of development properties
net of tax of $12,155, $10,824 and $4,401, respectively	25,121
Income from continuing operations	342,671
Discontinued operations:
Income from discontinued operating properties	14,004
Minority interest from discontinued operating properties	(1,497)
Loss on operating properties held for sale/sold	(1,421)
Gain on disposition of operating properties, net of tax	72,042
Income from discontinued operations	83,128
Gain on transfer of operating properties	1,394
Loss on transfer of operating property	-
Gain on sale of operating properties, net of tax	1,066
Total gain (loss) on transfer or sale of operating properties, net of tax	2,460
Net income	428,259
Preferred stock dividends	(11,638)
Net income available to common shareholders	$ 416,621

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The Company acknowledges that:

• the Company is responsible for the adequacy and accuracy of the disclosure in the filings;           

• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and

• the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Should you have any questions or require further clarification with regard to our responses, please feel free to contact me directly at (516) 869-7185.

Very truly yours,

/s/ Michael V. Pappagallo

Michael V. Pappagallo
Executive Vice President and
Chief Financial Officer

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