July 13, 2005



Mr. Mark A. Ruth
Principal Financial and Accounting Officer
Tengasco, Inc.
603 Main Avenue
Knoxville, Tennessee  37902


	Re:	Tengasco, Inc.
		Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 31, 2005
		Form 10-Q for Fiscal Quarter Ended March 31, 2005
      Filed May 11, 2005
		File No. 1-15555


Dear Mr. Ruth:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our 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.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may 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 December 31, 2004

Financial Statements

1. Net loss after the cumulative effect of changes in accounting
principles should be positioned before deducting dividends on
preferred stock necessary to arrive at net loss attributable to
common stockholders.

Summary of Significant Accounting Policies, page F-10

Oil and Gas Properties, page F-12

2. We note that you follow the full cost method for your oil and
gas
operations.  Please disclose the information required under
Regulation S-X, Rule 4-10(c)(7), applicable to registrants
following
the full cost method.

Concentration of Credit Risk, page F-15

3. You indicate that you are dependent on a small number of
customers
for the sale of gas from the Swan Creek Field and have a
concentration of credit risk with several customers.   Please
disclose revenues attributable to each single customer
contributing
10 percent or more or your total revenues to comply with paragraph
39
of SFAS 131.

Engineering Comments

Business, page 1

The Swan Creek Field, page 3

Swan Creek Production and Development, page 3

4. You state that the experienced decline in actual production
levels
from existing wells in the Swan Creek Field was expected and does
not
diminish either the shut-in pressure or the Company`s actual
reserves
in the field.  Please reconcile this statement to us, as to past
expectations and actual reserves, with the 41% negative gas
reserve
revision taken in 2004 and forecasts in both production levels and
reserves from past reserve reports.

Oil and Gas Reserves (unaudited), page F-32

5. We do not understand how, based on your past decline rate, you
will be able to recover the gas reserves that you report as proved
developed producing reserves.  Please clarify this for us.

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
the amendment to expedite our review.  Please furnish a cover
letter
with your 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 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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 Gary Newberry at (202) 551-3761, or Karl
Hiller,
Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the financial statements and related matters.  You may
contact James Murphy, Petroleum Engineer, at (202) 551-3703 with
questions about engineering comments.  Please contact me at (202)
551-3740 with any other questions.

								Sincerely,



								H. Roger Schwall
								Assistant Director

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Mr. Mark A. Ruth
Tengasco, Inc.
July 13, 2005
page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, N.E.
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
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