Room 4561
						  March 23, 2006

Stephen M. Bennett
President and Chief Executive Officer
Intuit Inc.
2700 Coast Avenue
Mountain View, CA 94043

Re:	Intuit Inc.
	Form 10-K for the Fiscal Year Ended July 31, 2005
	Filed September 26, 2005
	Form 10-Q for the Quarterly Period Ended October 31, 2005
	Filed December 5, 2005
	Form 10-Q for the Quarterly Period Ended January 31, 2006
	Filed March 9, 2006
	Form 8-K filed November 16, 2005
	File no. 0-21180

Dear Mr. Bennett:

      We have reviewed the above referenced filings and have the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  Where indicated, we
think you should revise your document in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  In some of our
comments,
we may ask you to provide us with supplemental information so we
may
better understand your disclosure.  After reviewing this
information,
we may or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.





Form 10-K for the Fiscal Year Ended July 31, 2005

Management`s Discussion & Analysis (MD&A) of Financial Condition
and
Results of Operations

Results of Operations, page 27

1. There are many instances where two or more sources of a
material
change have been identified, but the dollar amounts for each
source
that contributed to the change were not disclosed (i.e. revenue,
cost
of revenue and operating expenses).  Tell us what consideration
you
have given to quantifying each source that contributed to a
material
change pursuant to Section III. D of SEC Release 33-6835.  In
addition, tell us how you considered removing vague terms such as
"primarily" in favor of specific quantifications.

Notes To Consolidated Financial Statements

Note 1.  Summary of Significant Accounting Policies

Product Revenue, page 63

2. In page 5, you indicate that the Company offers a range of
financial supplies designed for small businesses, such as paper
checks, envelopes, invoices and deposit slips. We further note
from
your disclosures on page 13 that you use John H. Harland Company
exclusively to fulfill orders for all of your printed checks and
most
other products for your financial supplies business.  Tell us how
you
considered EITF 99-19 in accounting for revenue from the sale of
such
products.  Also, tell us if you hold any inventory for these
products.

Multiple Element Arrangements, page 63

3. We note that the Company offers several technical support plans
as
well as other services (i.e. web services, tax filing services,
consulting, training, etc.).  With regards to your multiple
element
arrangements, which include products and services please explain
the
following:
* Tell us how you account for arrangements that include product
and
technical support services (PCS).  For instance, tell us if the
product licenses are term licenses or perpetual licenses and tell
us
your accounting treatment for each.
* You indicate that if VSOE does not exist for undelivered items
that
are services, then you recognize the entire arrangement fee
ratably
over the service period.  Do you ever sell arrangements that
include
product and several service elements (i.e. PCS and training)?  If
so,
tell us how you account for such arrangements if you do not have
VSOE
for each of the undelivered service elements.  That is, tell us
how
you determine the service period over which you recognize revenue.
* Please provide examples of the specific products and services
that
fall within the categories on which the Staff is commenting.  For
instance, we note that service revenues include electronic tax
filing
services included in your consumer and professional tax products.
Do
you consider the products sold with such services to be multiple
element arrangements and if so, where do such products fall within
your policy discussion of multiple element arrangements?

Customer Service and Technical Support, page 64

4. You indicate that the Company does not defer the recognition of
revenue associated with sale of certain products, since the cost
of
providing the free technical support is insignificant.  Tell us
for
which products you do not defer technical support revenue and
provide
an analysis of the revenue from those product sales to the PCS
costs,
which supports your conclusions with regards to the significance
of
such costs.  Refer to paragraph 59 of SOP 97-2.

Note 4.  Goodwill and Purchased Intangible Assets, page 74

5. We note that the Company is amortizing certain intangibles,
such
as customer lists and purchased technology over a period of two to
seven years.  Provide a breakdown of these intangibles by their
useful lives.  For the portion of such assets that have useful
lives
of five years or beyond, tell us how you determined the adequacy
of
this amortization period.

Note 12.  Income Taxes, page 88

6. In page 34, you indicate that "reversal of reserves" for $25.7
million and $35.7 million in fiscal year 2005 and 2004,
respectively
is related to potential income tax exposures that were resolved.
Your disclosures in Note 1 indicate that the Company recognizes
liabilities for anticipated tax audit issues in the US and other
tax
jurisdictions based on your estimate of whether, and to the extent
to
which, additional taxes will be due.  Tell us how you applied the
guidance in SFAS 5 in determining the probability of the tax
position
being sustained on audit by the taxing authorities.  Did you
factor
in whether or not the tax position will be audited by the taxing
authorities in your assessment?  Tell us the amount of reserves
currently outstanding for pending tax positions and tell us what
consideration you have given to disclosing such reserves.  Please
provide a detailed explanation of the nature of tax issues that
resulted in such reserves and when the reserves were originally
recorded.  Also, tell us how you determined that the potential
income
tax exposure was resolved.




Form 10-Qs for the Quarterly Periods Ended October 31, 2005 and
January 31, 2006

7. With respect to the Company`s adoption of SFAS 123(R), please
explain the following:
* We note that the Company estimates the volatility of your common
stock based on the implied volatility of two-year publicly traded
options on your common stock.  Tell us how you considered each of
the
factors in Question 4 of SAB 107 in determining that use of the
implied volatility is appropriate.
* You indicate that for options granted before August 1, 2005, you
amortized the fair value on an accelerated basis.  Please confirm
that for awards granted prior to the adoption of SFAS 123R, you
are
continuing to calculate the compensation cost using the
attribution
method that was used under SFAS 123 in your pro forma disclosures.
See paragraph 74 of SFAS 123R.

Form 8-K filed November 16, 2005

8. We note your use of non-GAAP measures under Item 9.01 of the
Form
8-K noted above which excludes a number of recurring items.  Tell
us
how you considered Question 8 of Frequently Asked Questions
Regarding
the Use of Non-GAAP Financial Measures to include the following
disclosures for each of your non-GAAP measures (i.e. non-GAAP cost
of
product revenue, non-GAAP cost of service revenue, non-GAAP
research
and development, non-GAAP income tax benefit, etc.):
* the manner in which management uses the non-GAAP measure to
conduct
or evaluate its business;
* the economic substance behind management`s decision to use such
a
measure;
* the material limitations associated with use of the non-GAAP
financial measure as compared to the use of the most directly
comparable GAAP financial measure;
* the manner in which management compensates for these limitations
when using the non-GAAP financial measure; and
* the substantive reasons why management believes the non-GAAP
financial measure provides useful information to investors.

In this regard, we believe you should further enhance your
disclosures to comply with Item 10(e)(1)(i)(C) and (D) of
Regulation
S-K and Question 8 of the related FAQ to demonstrate the
usefulness
of your non-GAAP financial measures which excludes a number of
recurring items, especially since these measures appear to be used
to
evaluate performance.  Your current disclosures regarding the
reasons
for presenting these non-GAAP measures appear overly broad
considering that companies and investors may differ as to which
items
warrant adjustment and what constitutes core operating results.


	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Kari Jin, Staff Accountant, at (202) 551-
3481
or me at (202) 551-3730 if you have questions regarding these
comments.


Sincerely,


      Kathleen Collins
      Accounting Branch Chief
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Mr. Stephen M. Bennett
Intuit Inc.
March 23, 2006
Page 1