222 NORTH LASALLE STREET                                  CHICAGO, ILLINOIS 60601                                  T: +1 (312) 609 7500                                  F: +1 (312) 609 5005                                  CHICAGO — NEW YORK — WASHINGTON, DC — LONDON — SAN FRANCISCO
NATHANIEL SEGAL ATTORNEY AT LAW nsegal@vedderprice.com

October 10, 2013

VIA EDGAR

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

Re: Nuveen Massachusetts Premium Income Municipal Fund (the “Registrant”);

File No. 333-190942

To the Commission:

On behalf of the Registrant, electronically transmitted herewith is the Registrant’s Pre-Effective Amendment No. 1 to its Registration Statement on Form N-14 (the “Amendment”) relating to the issuance of common shares and MuniFund Term Preferred Shares (“MTP Shares”) in connection with the reorganizations of Nuveen Massachusetts AMT-Free Municipal Income Fund and Nuveen Massachusetts Dividend Advantage Municipal Fund into the Registrant (the “Reorganizations”).

The Amendment incorporates revisions to the Registrant’s Registration Statement on Form N-14 filed on August 30, 2013 relating to the issuance of common shares and MTP Shares in connection with the Reorganizations (the “Registration Statement”), in response to comments provided telephonically by the staff of the Securities and Exchange Commission to Vedder Price P.C. on September 30, 2013, with respect to the Registration Statement (as addressed in separate correspondence to the staff dated October 10, 2013). The Amendment is also being filed for the purpose of providing certain information required by the Form and not included in the Registration Statement and to make certain other non-material changes.

Please contact the undersigned at (312) 609-7747 if you have questions or comments regarding the filing.

Very truly yours,

/s/ Nathaniel Segal

Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, and with Vedder Price (CA), LLP, which operates in California.