January 28, 2020

Stewart Glendinning
Executive Vice President and Chief Financial Officer
TYSON FOODS, INC.
2200 West Don Tyson Parkway
Springdale, Arkansas 72762

       Re: TYSON FOODS, INC.
           Form 10-K for the fiscal year ended September 28, 2019
           10-K filed November 12, 2019
           File No. 001-14704

Dear Mr. Glendinning:

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

       Please respond to our comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the fiscal year ended September 28, 2019

Management's Discussion and Analysis of Financial Conditions and Results of
Operations
Summary of Results
Cost of Sales 2019 vs. 2018, page 26

1.    We note your disclosure of a $60 million increase in raw material costs
in your Prepared
      Foods segment. In your earnings call on November 12, 2019 you appear to
indicate that a
      driver of the increase was related to issues with your SAP installation.
In addition, you
      also note on the call that the SAP installation may also be a driver of a
sizable adjustment
      of your inventory levels. To help us better understand your statements in
your earnings
      call and its related impact on your financial statements, please describe
for us in greater
      detail the nature of the issue(s) associated with the the SAP
installation and its related
      impact to your financial statements, including the effect on your
inventory levels which
      notably increased in 2019. As part of your response, please tell us the
periods affected and
      quantify the amount for each item identified. Please also tell us if the
underlying
 Stewart Glendinning
TYSON FOODS, INC.
January 28, 2020
Page 2
         implementation issues have been resolved or, if not, what your
assessment of the potential
         impact is for future reporting periods.
       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 Charles Eastman, Staff Accountant, at (202) 551-3794 or
Jean Yu,
Assistant Chief Accountant, at (202) 551-3305 with any questions.



FirstName LastNameStewart Glendinning                         Sincerely,
Comapany NameTYSON FOODS, INC.
                                                              Division of
Corporation Finance
January 28, 2020 Page 2                                       Office of
Manufacturing
FirstName LastName