Berkshire Income Realty, Inc.
One Beacon Street, Suite 1500
Boston, MA 02108
October 22, 2008
Mr. Jorge Bonilla
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Comment Letter dated October 9, 2008 (the “Comment Letter”), in respect of:
Berkshire Income Realty, Inc.
Form 10-K for Year Ended December 31, 2007
Form 10-Q for Quarter Ended March 31, 2008 and June 30, 2008
File No. 001-31659
Dear Mr. Bonilla:
Berkshire Income Realty. Inc (the “Company”) respectfully submits the following response to the comment of the United States Securities and Exchange Commission Staff contained in the Comment Letter:
The Company will revise the beginning of the certification required by Exchange Act Rule 13a-14(a) in future filings by excluding the title from the identification of the certifying individual(s).
The Company acknowledges that:
| · | the Company is responsible for the adequacy and accuracy of the disclosures 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. |
If you have any questions with regard to this response, need further information or would like to discuss the matter covered in this letter, please contact me at (617) 556-1450.
Sincerely,
/s/ Christopher M. Nichols
Christopher M. Nichols
Principal Financial Officer
