December 10, 2004


VIA EDGAR and FACSIMILE (Correspondence Filing)

Mark Cowan
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.  (Mail Stop 5-6)
Washington, D.C. 20549-1004

ATTN:      Document Control - Edgar

RE:        IDS Life of New York Account 8 ("Registrant")

           IDS Life of New York Succession Select Variable Life Insurance
           Post-Effective Amendment No. 11
           On From N-6 (File No. 333-42257)
           Investment Company Act No. 811-05213

           IDS Life of New York Variable Universal Life IV/IDS Life of New York
           Variable Universal Life IV - Estate Series and IDS Life of New York
           Variable Universal Life III
           Post-Effective Amendment No. 10
           On Form N-6 (File No. 333-44644)
           Investment Company Act No. 811-05213

           IDS Life Of New York Variable Universal Life Insurance
           Post-Effective Amendment Nos. 25 and 26
           On Form N-6 (File No. 33-15290)
           Investment Company Act No. 811-05213

Dear Mr. Cowan:

This letter is in response to Staff's oral comments sent via voicemail on or
about December 10, 2004 for the Registrant and Post-Effective Amendments
(collectively, the "Amendments") listed above. Staff had no comments except the
requirement to make the following representation on behalf of the Registrant:

In connection with the Amendments, IDS Life Insurance Company of New York, (the
"Company") on behalf of the Registrant, hereby acknowledges the following:

         The disclosures in the filing are the responsibility of the Company and
         the Company is fully responsible for the adequacy or accuracy of the
         disclosures in this filing. The Company represents to the Commission
         that comments made by the Commission, or the staff acting pursuant to
         delegated authority, or changes to disclosure in response to staff
         comments in the filing reviewed by the staff, do not foreclosure the
         Commission from taking any action with respect to the filing, and the
         Company represents that it will not assert this action as a defense in
         any proceeding initiated by the Commission or any person, under the
         federal securities laws of the United States.

If you have any additional questions, please call Mary Ellyn Minenko at
612-671-3678 or Simone Pepper at 612-671-2847.

Sincerely,

/s/  Heather M. Somers
- -----------------------
     Heather M. Somers
     General Counsel
     IDS Life Insurance Company of New York



Cc:      Mary Ellyn Minenko
         Simone Pepper