April 15, 2005

via facsimile and U.S. mail
Mr. Douglas W. Weir
Chief Financial Officer
Toreador Resources Corporation
4809 Cole Avenue, Suite 108
Dallas, Texas 75205

	Re:	Toreador Resources Corporation
		Form 10-K, for the year ended December 31, 2004
      File No. 0-02517


Dear Mr. Douglas W. Weir:


      We have reviewed the above filing and have the following
accounting.  We have limited our review to only the matters
addressed
below and will make no further review of your document. Comments
relating to engineering matters, if any, will be issued in a
separate
letter. 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.












10-K for the year ended December 31, 2004


Critical Accounting Policies, page 32

1. We note that you have duplicated your significant accounting
policies as presented in note 2 to your financial statements under
your critical accounting policies.   Critical accounting policy
disclosures should supplement, not duplicate, the description of
accounting policies that are already disclosed in the notes to the
financial statements.  Such disclosures should address the
specific
instances where uncertainties exist in your estimates that
materially
affect the quality and variability of your earnings and cash flows
so
that investors may ascertain the indicative value of your reported
financial information. We generally find that disclosures
including
both a sensitivity analysis and discussion of historical
experience
in making critical estimates are effective in conveying this
information.  Please modify your disclosures accordingly.  Refer
to
FRC Section 501.14 for further guidance.

Financial Statements

Consolidated Statements of Changes in Stockholders` Equity, page
F-6

2. We note that your share data related to share transactions was
not
included in your statement of stockholders` equity.  Please modify
your statement of stockholder`s equity to include share data or
provide a tabular presentation of changes in your outstanding
shares
in the notes to your financial statements.  Refer to paragraph 10
of
ABPO No. 12.

Notes to Consolidated Financial Statements, page F-12

3. We have read your revenue recognition policy disclosure and
were
unable to determine how you are accounting for oil sales and
transportation costs associated with your sales. We would expect
your
disclosures to include a description of significant contract terms
and how you have applied the guidance in SAB Topic 13A to your
sale
arrangements.  For example, we note your disclosure that a
significant portion of your oil production is sold to Elf Antar
France S.A. Additionally, whether you have accounted for the
transportation costs as a component of your oil sales or selling
expenses should be clear from your disclosures.  Please expand
your
revenue recognition policy accordingly.



Closing Comments

      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.  You may wish to provide us with marked copies of
amendments to expedite our review.  Please furnish a cover letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
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 the 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(s);

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 Jon Duersch at (202) 942-1761 or Jill Davis
at
(202) 942-1996 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
942-1870 with any other questions.  Direct all correspondence to
the
following ZIP code:  20549-0405.

							Sincerely,



							H. Roger Schwall
							Assistant Director
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Toreador Resources Corporation.
April 15, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE