Mail Stop 4561

						December 29, 2005

VIA U.S. MAIL AND FAX (301)468-3180

H. William Willoughby
Director, President and Secretary
Capital Realty Investors II, LTD Partnership
11200 Rockville Pike
Rockville, Maryland 20852

Re:	Capital Realty Investors II, LTD Partnership
	File No. 000-11973
      Form 10-K for Fiscal Year Ended
	December 31, 2004
	Form 10-Q for Quarterly Periods Ended
	March 31, 2005, June 30, 2005 & September 30, 2005

Dear Mr. Willoughby:

      We have reviewed your filing and have the following comment.
In our comment, we may ask you to provide us with supplemental
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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



Exhibit 99 Reports of Other Auditors

1. With respect to the audits performed of your limited
partnerships
tell us how you considered PCAOB Release 2003-007 and the fact
that
under this rule, "all U.S. public accounting firms must be
registered
with the Board if they wish to prepare or issue audit reports on
U.S.
public companies, or to play a substantial role in the preparation
or
issuance of such reports, after October 22, 2003."  Additionally
tell
us how your other auditors considered the need to refer to PCAOB
audit standards in their reports in accordance with PCAOB AS #1.



*    *    *    *

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your response to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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 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.


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 filings or in response
to
our comments on your filings.

      You may contact Robert Telewicz, Staff Accountant, at (202)
551-3438 or the undersigned at (202) 551-3414 if you have
questions.



								Sincerely,



      Jorge L. Bonilla
      Senior Staff Accountant



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H. William Willoughby
Capital Realty Investors II, LTD. Partnership
December 29, 2005
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