September 26, 2018

Kevin Kremke
Chief Financial Officer
Delek US Holdings, Inc.
7102 Commerce Way
Brentwood, TN 37027

       Re: Delek US Holdings, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           File No. 001-38142

Dear Mr. Kremke:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Operating Segments, page 77

1.    We note you calculate gross margin for each of your segments by
subtracting cost of
      goods sold from net sales. If your presentation of gross margin does not
include
      depreciation and amortization or other costs directly attributable to the
generation of
      revenue, we believe the calculation would be a non-GAAP measure.
Accordingly, revise
      your presentation to either include any excluded costs or to use a
different title that
      distinguishes the non-GAAP measure from gross margin as determined in
accordance
      with GAAP. To the extent you continue to report it as a non-GAAP measure,
include all
      the disclosures required by Item 10(e) of Regulation S-K.
 Kevin Kremke
Delek US Holdings, Inc.
September 26, 2018
Page 2
2.       You define refining margin for your refining segment as the difference
between the cost
         of crude oil feedstocks you purchase and the price of the refined
products you sell. Please
         clarify how your calculation of refining margin differs from your
gross margin measure
         for the refining segment.
Financial Statements
Consolidated Statements of Income, page F-5

3.       Your presentation of cost of goods sold appears to exclude
depreciation and amortization.
         If you rely upon the accommodation outlined in SAB Topic 11:B in
excluding
         depreciation and amortization from certain cost and expense
categories, you should report,
         either on separate lines or parenthetically, the amounts of
depreciation and amortization
         that are attributable to each line item from which it has been
excluded.
4.       Information in various parts of your filing indicates that you
generate revenue from the
         sale of products and services. Given this, explain to us how you have
considered
         separately disclosing on the face of your income statement net sales
of tangible products
         and revenue from services, as well as cost of tangible goods sold and
cost of services. See
         Rules 5-03.1 and 5-03.2 of Regulation S-X.
5.       Explain to us the specific cost items included in your income
statement line items Cost of
         Goods Sold and Operating Expenses. To the extent that Cost of Goods
Sold does not
         include all costs directly attributable to sales of products and
revenue from services, other
         than as contemplated by SAB Topic 11.B, explain to us how your current
presentation
         complies with the requirements of Rule 5-03.2 of Regulation S-X.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Jenifer Gallagher, Staff Accountant at (202) 551-3706 or
Brad Skinner,
Senior Assistant Chief Accountant at (202) 551-3489 with any questions.



FirstName LastNameKevin Kremke                                  Sincerely,
Comapany NameDelek US Holdings, Inc.
                                                                Division of
Corporation Finance
September 26, 2018 Page 2                                       Office of
Natural Resources
FirstName LastName