June 1, 2007



Ms. Nudrat Salik
Staff Accountant
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549

	Re:	Scott's Liquid Gold-Inc.
		Form 10-KSB for the fiscal year ended December 31, 2006
		File No. 1-13458

Dear Ms. Salik:

	This letter responds to the comments of the staff of the Securities
and Exchange Commission in its letter dated April 26, 2007 with respect
to the Form 10-KSB Report listed above.  The text of the staff's comments
is set forth below in bold followed in each case by the response.

FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2006

General

1.	Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response what
the revisions will look like.  These revisions should be included in your
future filings.

	Response:	The responses below include proposed revisions to
disclosures in future filings where applicable.

Item 6.  Management's Discussion and Analysis

Results of Operations, page 16

2.	You state on page 19 that cost reductions were initiated in the
third and fourth quarters of 2006, including a reduction in the number of
employees and salary reductions for officers and certain employees.  You
estimate that these measures will result in a cost savings of approximately
$700,000 on an annualized basis.  Please clarify whether you incurred any
employee termination costs or other types of restructuring costs
associated with these cost reductions.  If so, please provide the
disclosures required by paragraph 20 of SFAS 146 as well as SAB
Topic 5:P.4.

	Response:	We did not incur any restructuring costs associated
with these cost reductions. We did provide a few weeks severance pay to
the terminated employees.  This severance pay was expensed during the
period involved. There were no costs incurred which carried over to
future periods.

Financial Statements

Notes to Financial Statements

Note 1.  Organization and Summary of Significant Accounting Policies

(k)  Revenue Recognition, page 29

3.	Reserves for returns and allowances are recorded as a reduction of
revenue, and are maintained at a level that management believes is
appropriate to account for amounts applicable to existing sales.  On
page 4, you state that a recent practice of retailers has been to return
products that have either been discontinued or not sold after a period
of time.  On page 17 of MD&A, you state that net sales of the new Alpha
Hydrox products declined in 2006 compared to 2005 as a result of returns
from one retailer in the second quarter as well as other factors.  We
also note a significant decline in Montagne Jeunesse products.  Please
help us further understand your accounting of estimated product returns
by addressing the following:

	.  Please disclose whether there is a limited or indefinite period
of time during which you allow returns.  Please clarify whether all of
your products are subject to the same return policies or whether
different products are subject to different policies;

	.  Please provide us with a history of returns for the years 2003
through 2006 and the first quarter of 2007, by product category.  Provide
explanations for indicated trends; and

	.  Please explain to us how you determined you meet the criteria of
paragraph 6 of SFAS 48 at the time of sale to record revenue related to
your products.  Please provide separate explanations for your skin care
products and your household products.  Please discuss your consideration
of the factors included in paragraph 8 in determining that the amount of
future returns can be reasonably estimated as well as any other factors
you consider appropriate in your industry.  Please also address your
consideration of the introduction of new products, which you discuss on
page 2, that may result in larger than expected returns of current
products.

	Response:	The Company manufactures and/or distributes two
different consumer product lines - household chemicals and skin care.
With respect to both lines of products, the company publishes standard
price lists from which discounts may be granted based upon order sizes
or annual purchase volumes, etc.  which are negotiated with the retail
customer.  Product is shipped and invoiced in response to the terms
(timing, destination, pricing, payment terms, etc.) as stated on the
purchase orders issued by the buyer.   If any of the terms on a purchase
deviate from those previously negotiated with the customer, the purchase
order is rejected and a new purchase order must be obtained with the
correct terms.   Payment terms are typical in that they state the
number of days permitted until payment is considered past due and may
include discount for early payment.  The timing of invoice payment is
unrelated to any subsequent sales conditions or events of the customer.

Household Chemicals - With respect to these products, returns are
permitted for only a limited time and, generally, returns are only
allowed with respect to manufacturing defect.  There may be exceptions
in which a particular variety of product is just not compatible with a
retailer's demographics.  In such cases, the resolution is usually an
exchange of product for a more suitable variety.  We have been in the
household products business for over 55 years and we have historically
experienced very minimal return activity as supported by the experience
over the past four years in which return levels have ranged from a low
of 0.23% to 0.40% on sales volumes ranging from $9.5 million to $10.2
million as seen in the data below:

Year		Sales Volume	Returns  	  %
- -------     ------------      -------     -----
2003		$ 9,470,600		$29,600	0.31%
2004		$10,231,500		$40,500	0.40%
2005		$ 9,451,800		$27,200	0.23%
2006		$ 9,559,400		$30,700	0.32%
2007(Q1)	$ 2,605,100		$ 4,900	0.19%

We maintain a small reserve for returns against our sales of household
products that is estimated as a percentage of sales taking into account
both historical experience and current information.  This reserve has
been adequate for these product returns.

Skin Care - With respect to these products, and as a result of competitive
pressures, skin care products throughout the industry are sold with an
unwritten "right of return" such that product will be repurchased if not
sold through to the consumer.  Not all retailers enforce this "industry
standard" yet the major chains are very diligent to do just that.  As a
practical matter it is not feasible to establish the point in time when
"sell through" to the consumer has occurred and thus we recognize revenue
at the time our product is delivered pursuant to an existing arrangement
(subject to the establishment of a reserve for returns).  Applying
historical experience and considering current information, the Company
has established a reserve for its estimated returns and reviews the
overall level of the reserve on a quarterly basis.

The Company's skin care business is comprised of a manufactured line of
premium cosmetics and a line of value priced skin care products which it
distributes for an unrelated foreign manufacturer.

With respect to the value priced skin care products, which are comprised
primarily of single use sachets with a retail price point of below $4,
the return history as shown below is quite minimal.  This product's
success is the result of the low price point and the large variety of
"flavors" that are available.  Because the products are inexpensive,
consumers are not predisposed to return products that they do not care
for.  They simply select another of the variety in the future.  However,
lack of favor with the consumer shows up in lack of recurring sales of
a given flavor.  The lack of recurring sales may prompt the retailer to
discontinue one flavor and select another (generally an exchange of
offering) from the wide variety available for sale by the Company.  Due
to the low cost of this product to the Company, disposal of less popular
selections has been readily accomplished through the "close-out" retail
sector at or above our cost.  Periodically, a flavor that may not sell
well in this country is popular in another.  In such cases we have been
able to sell product back to our vendor.

Year		Sales Volume	Returns  	  %
- -------     ------------      -------     -----
2003		$12,333,000		$209,500	1.7%
2004		$ 1,342,400		$244,900	2.2%
2005		$11,456,500		$407,000	3.6%
2006		$ 5,436,100		$197,800	3.6%
2007(Q1)	$ 1,034,000		$ 26,400	2.6%

The dramatic sales decline reflected above in 2006 is a direct result of
a major retailer's decision to substantially reduce and/or eliminate the
department within their stores where this product was merchandised in
spite of our product being one of the most successful lines in the
department.  This retailer subsequently reinstated and repositioned
the product in early 2007.

Due to the minimal levels of returns on these products, we maintain a
modest reserve for returns against our sales of skin care products,
calculated as a percentage of gross sales, which considers both
historical experience and current information.  Our estimated reserves
have been adequate for these product returns.

With respect to the skin care products that we manufacture, the product
line is at a price-point where significantly more competitors are at
play and where a broader variety of technologies are being presented
as the most effective solution for the treatment of various skin
deficiencies.  A large part of these products are sold by the drug store
and grocery chains who are highly sensitive to unit sales volumes and
quick to pull the plug on a product line.  Because many of the
competitors in this arena are larger and have substantial assets to
support aggressive advertising campaigns, they are able to better
sustain the sales volume these retailers are looking for.  Consequently,
our products are more prone to discontinuation or return at such
retailers.  In the specialty store area (beauty specific retailers) our
gross sales volumes have maintained consistency ($300K to $400K at one
retailer alone).  Our line of diabetic skin care has been consistent as
well running sales volumes near the $1.5 million range.  Our product
returns in the specialty store area and diabetic skin care have been
minimal.

Our new product introduction in 2005 generated gross sales of
approximately $3 million which declined to $2 million in 2006 largely
reflective of the initial pipeline fills in 2005 not to be repeated in
2006.  Our "original" cosmetic line, first introduced in 1992 and which
achieved peak sales volumes in excess of $30 million in 1997, has
steadily declined to the point that by 2004 had dropped to around
$3 million and further dropping to near $2 million in 2006.  This
volume slide on our original product reflects the reduced number of
outlets at which our product may be found.  As a direct result of the
reduced presence in retail across the nation, our faithful consumers
continue to find their way to our company web site where sales have
steadily climbed reaching nearly $700K in 2005 and $800K in 2006.
Returns at our web site are essentially non-existent.

When you look at the total sales below of our manufactured skincare
products and factor out the stable and/or growing sectors (Diabetic,
specialty store and web site), product sales which remain and are the
primary source of return activity range from $2 million to $3 million.
Returns experienced in 2005 and 2006 ran between 5% to 10% of these
remaining sales volumes.


Year		Sales Volume	Returns  	  %
- -------     ------------      -------     -----
2003		$ 6,362,700		$971,900	15.3%
2004		$ 4,545,000		$347,300	 7.6%
2005		$ 7,110,400		$221,000	 3.1%
2006		$ 5,374,100		$422,200	 7.9%
2007(Q1)	$ 1,599,000		$ 23,700	 1.5%

We maintain a returns reserve, which management reviews on a quarterly
basis, taking into account both historical experience and current
information, in an amount we believe is appropriate to provide for the
likely return activity related to previously recognized sales of our
skin care products.  Our estimated reserves have been adequate for these
products.

4. 	Please expand your revenue recognition policy to address all of
the criteria of SAB Topic 13:A.1 in a similar manner to your Critical
Accounting Policies on page 15.  Please clarify what you mean when
you state that generally your revenue recognition criteria is that
there be an arrangement to sell the product, you have delivered the
product in accordance with that arrangement, the sales price is
determinable, and collectibility is probable.

Response:	The first sentence of the footnote to the financial
statements "(k) Revenue Recognition" as appears on page 29 of the
Company's Form 10-KSB filing currently reads as follows:

	"Revenue is generally recognized upon delivery of products to
customers, which is when title passes."

	We would propose that in future filings the above sentence would
be superseded by the follow passage:

	"Revenue is recognized when an arrangement exists to sell our
product, we have delivered such product in accordance with that
arrangement, the sales price is determinable, and collectibility is
probable."

Note 2.  Inventories, page 32

5. 	On page 17 of MD&A, you state during the first quarter of 2005 you
began introduction of four new items in your Alpha Hydrox line of
cosmetic products.  This resulted in "pipeline" orders of the new items
in 2005 that were not repeated in 2006.  Net sales of the new Alpha
Hydrox products declined in 2006 compared to 2005 as a result of returns
from one retailer in the second quarter, the filling of store shelves
with the introduction of the product in 2005, and higher couponing and
co-op advertising costs that are deducted from gross sales.  You have
continued to experience a drop in unit sales of your earlier established
alpha hydroxy acid-based products due primarily to maturing in the
market for alpha hydroxy acid-based skin care products, intense
competition from producers of similar or alternative products, many of
which are considerably larger than Neoteric Cosmetics, Inc. and reduced
distribution of these products at retail stores in current and prior
periods.  We also note the steep drop in Montagne Jeunesse products in
2006, due to reduced product positioning at several key retailers.  You
state that you estimate reserves for slow moving and obsolete products
and raw materials based upon historical and anticipated sales.  Please
provide us with a breakdown of your inventory and inventory reserve for
obsolescence by product line as of December 31, 2006.  Please tell us
what consideration you gave to the decline in unit sales and other noted
trends in determining the appropriate reserve to record for this inventory.
Refer to Statement 5 of Chapter 4 of ARB 43.

	Response:	In considering unfavorable trends in unit sales in
reserves for inventory we look at our inventory for those suspect items
and consider the likelihood that either through future sales of those
products through our existing customer base or through close-out channels
whether we will realize the value in our inventory.  We also continually
analyze our raw material purchasing to match as closely as possible what
we are experiencing in sales volume. Historically we have not disposed
of and thus written off much of our finished goods inventory as we have
either sold it though existing channels, a close-out type retailer,
and/or sales through our website where we continue to sell items not
readily available at retail outlets.

		Regarding finished goods we realized at the end of 2006 that
one variant of our Montagne Jeunesse line of skin care sachets was over
valued based on our review of sales of that variant and the likelihood
of future sales at/or above our cost, that the value of that inventory
was too high thus we reserved a significant portion of that cost.

		Our reserves also include reserves for raw materials.  We
review our raw materials inventory, again based on our sales and
usage.  The majority of these reserves, based on that review, pertain
to packaging we believe will change before we use it up or chemicals
which we will not use before they expire.  In 2006 we reserved an
additional amount of approximately $20,000 for chemicals which we
believe will expire prior to their use.

		Below is our breakdown of inventory and reserves:

                   Scott's Liquid Gold-Inc. and Subsidiaries
                               December 31, 2006

                     Inventory by
                     Product Line
                ----------------------
                    Raw      Finished
                  Material    Goods     Subtotal    Reserves     Total
                 ---------   ---------  ---------  ---------   ---------
Scott's Liquid
Gold and other
household
products           516,700     558,500  1,075,200    (22,700)  1,052,500

Touch of
Scent              177,100     117,100    294,200     (5,700)    288,500

Alpha Hydrox
and other skin
care products      492,800     524,500  1,017,300   (186,300)    831,000
Montagne
Jeunesse skin
care products      150,600   1,235,300  1,385,900   (266,500)  1,119,400
                 -------------------------------------------------------
                 1,337,200   2,435,400  3,772,600   (481,200)  3,291,400
                 =======================================================

Item 8A.  Controls and Procedures, page 40

6. 	You state that your disclosure controls and procedures were
effective to ensure that information required to be disclosed by you
in reports that you file or submit under the Exchange Act is recorded,
processed, summarized and reported within the time periods specified in
the Securities and Exchange Commission rules and forms.  This is an
incomplete definition of disclosure controls and procedures per Rules
13a-15(e) and 15d-15(e) of the Exchange Act.  Please either state your
conclusion while providing the complete definition of disclosure controls
and procedures, or alternatively, simply state that your disclosure
controls and procedures are effective, or not effective, without
providing any part of the definition of disclosure controls and procedures
that is included in Exchange Act Rules 13a-15(e) and 15d-15(e).  Please
also confirm to us that your disclosure controls and procedures were
effective as of December 31, 2006 when evaluating based on the complete
definition of disclosure controls and procedures.

	Response:	In the item on "Controls and Procedures," we will
state in future filings that the disclosure controls or procedures are
effective, or are not effective, as of a specific date, such as:  Based
on that evaluation, the Chief Executive Officer and Chief Financial
Officer concluded that our disclosure controls and procedures are
effective.

We also confirm that our disclosure controls and procedures of the
Company were effective as of December 31, 2006, using the complete
definition of disclosure controls and procedures.

	We acknowledge that:
	.  Our 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

	.  Our 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.

	If you have any questions or comments regarding the foregoing,
please contact Mark R. Levy (303-295-8073) or Amy Bowler (303-295-8337)
at Holland & Hart LLP, our attorneys.  Thank you.

Very truly yours,

SCOTT'S LIQUID GOLD-INC.




By:	/s/ Jeffry B. Johnson
      -------------------------------------
	Jeffry B. Johnson
	Treasurer and Chief Financial Officer