December 29, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail
J.B. Hunt Transport Services, Inc.
Jerry W. Walton, Chief Financial Officer
615 J.B. Hunt Corporate Drive
Lowell, Arkansas 72745

		Re:	J.B. Hunt Transport Services, Inc.
			Form 10-K for the Year Ended December 31, 2004
       			File 000-11757

Dear Mr. Walton:

      Based upon an examination restricted solely to
considerations of
the Financial Statements, Management`s Discussion and Analysis,
and
Selected Financial Data, the staff has the following comments on
the
above-referenced documents.  Where indicated, we think you should
revise your future filings 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.
Form 10-K For the Fiscal Year Ended December 31, 2004

Item 7- Management Discussion and Analysis, page 12

1. It appears that fuel surcharges had a material effect on
segment
revenues.  Since the effect of these charges varies greatly from
amongst segments, please consider revising your MD&A to include a
table that details revenues derived from fuel surcharges and
"base"
revenues, for each of your reportable segments, as well as the
changes
from period to period.


Item 8- Financial Statements and Supplementary Data

Consolidated Statement of Earnings, page 32

2. Consistent with the reporting treatment presented by other
trucking
companies and the fact that "fuel surcharge" revenues appear to
vary
materially from period-to-period, we believe you should separately
classify these revenues from your "base" revenues on the
consolidated
statements of operations.

Note 1- Business, page 35

3. You state that you are one of the largest logistics companies
in
North America.  However, based on the disclosures on page 47, you
contributed your entire logistics segment and all related
intangible
assets to acquire a 27% interest in Transplace Inc.  Therefore, it
would appear that you are no longer in the transportation
logistics
business.  Please advise or revise to clarify.

Note 2- Summary of Significant Accounting Policies

Property, Plant and Equipment, page 36

4. Please tell us your spare parts and supplies balance as well as
how
you classify these amounts on your statement of position.  If
material, revise future filings to disclose your accounting policy
regarding spare parts and supply within the notes to the financial
statements.

Revenues Recognition, page 36

5. Based on disclosures on page 7, approximately 11% of your
tractor
operators are independent contractors.  As such, please tell us
how
you structure these arrangements and whether you account for them
on a
"net" or "gross" basis, in accordance with EITF 99-19.
Additionally,
please expand your revenue recognition policy to specifically
detail
whether you account for these arrangements on a "net" or "gross"
basis.

6. Please tell us, in detail, the nature of the contract
agreements
within your dedicated contract services segment and how they
differ
from those in other segments.




	As appropriate, respond to these comments within 15 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 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.

      Pursuant to Rule 101(a)(3) of Regulation S-T, your response
should be also be submitted in electronic form, under the label
"corresp" with a copy to the staff.

	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 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 Juan Migone at (202) 551-3312 or undersigned
at
(202) 551-3211 if you have questions regarding comments on the
financial statements and related matters.


      Sincerely,


      David R. Humphrey
      Branch Chief-Accountant
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Jerry W. Walton, Chief Financial Officer
J.B. Hunt Transport Services, Inc.
December 29, 2005
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