May 6, 2005


Mail Stop  05-11

John Daly, President
Humana Trans Services Holding Corp.
7466 New Ridge Road, Suite 7
Hanover, Maryland  21076


Re:	Form 8-K filed 05/04/05
	File No.  000-30734

Dear Mr. Daly:

	We have reviewed your filing and have the following comments.
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.  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 the applicable staff person at the
telephone number listed at the end of this letter.

1.  Please amend the Form 8-K to state the your former accountant
was
dismissed as required by Item 304(a)(1)(i) of Regulation S-B.

2.  We have read your disclosure regarding the reports issued.
Please note that this disclosure should only cover the period the
former accountant was retained.  Please specifically identify the
period the former accountant was retained and whether they only
reviewed financial information or whether a report was issued.  If
a
report was issued please disclose the period the report covered
and
whether the report contained an adverse opinion, a disclaimer of
opinion, or was modified as to uncertainty, audit scope or
accounting
principles, including the ability to continue as a going concern.
Please revise.

3.  We have read your disclosure regarding disagreements with the
former accountant.  Please note that this disclosure should only
cover the period the former accountant was retained.  Please
disclose
whether there were disagreements between the Company and the
former
accountant for the period the accountant was retained through the
date of dismissal.  Please revise accordingly.

4.  Please file an updated letter from your former accountant
stating
whether the accountant agrees with your Item 304 disclosures, or
the
extent to which the accountant does not agree.  Refer to Item
304(a)(3) of Regulation S-B.

      Please file your supplemental response and amendment via
EDGAR
in response to these comments within 5 business days after the
date
of this letter.  Please contact the staff immediately if you
require
longer than 5 business days to respond.

      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 registrant and its management are
in
possession of all facts relating to a registrant`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 registrant acknowledging that:
* the registrant 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 registrant 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.

Direct any questions regarding this letter to Angela Halac at
202.551.3398


Sincerely,


Angela J. Halac
Staff Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE