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                            December 19, 2022

       Brian Mitts
       Interim President and Chief Financial Officer
       Vinebrook Homes Trust, Inc.
       300 Crescent Court, Suite 700
       Dallas, TX 75201

                                                        Re: Vinebrook Homes
Trust, Inc.
                                                            Form 10-K for the
fiscal year ended December 31, 2021
                                                            Filed February 23,
2022
                                                            Form 10-Q for the
quarterly period ended September 30, 2022
                                                            Filed November 14,
2022
                                                            File No. 000-56274

       Dear Brian Mitts:

              We have limited our review of your filings 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, 2021

       FFO, Core FFO and AFFO, page 67

   1.                                                   We note that you
reconcile funds from operations (FFO) from net income (loss)
                                                        attributable to common
stockholders and net income (loss) attributable to NCI in the OP.
                                                        Based upon your
reconciliation, it appears that FFO represents FFO attributable to
                                                        common shareholders and
NCI in the OP. Please revise your presentation in future filings
                                                        to clearly label FFO as
FFO attributable to common shareholders and NCI in the OP.
       Form 10-Q for the quarterly period ended September 30, 2022

       Item 6. Exhibits
       Exhibit 32.1, page 61
 Brian Mitts
Vinebrook Homes Trust, Inc.
December 19, 2022
Page 2
2.       Please amend your filing to include the certification pursuant to
Securities Exchange Act
         of 1934 Rule 13a-14(b) or 15d-14(b) pertaining to 18 U.S.C. Section
1350, as adopted
         pursuant to Section 906 of the Sarbanes-Oxley Act of 2002. Please
ensure your
         certification identifies the correct periodic report of the
certification. This comment also
         applies to your quarterly report for the quarter ended June 30, 2022.
       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 Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or
Isaac Esquivel,
Staff Accountant, at (202) 551-3395 with any questions.



FirstName LastNameBrian Mitts                                   Sincerely,
Comapany NameVinebrook Homes Trust, Inc.
                                                                Division of
Corporation Finance
December 19, 2022 Page 2                                        Office of Real
Estate & Construction
FirstName LastName