Anderson-Tully Company 1242 North Second Street Memphis, Tennessee 38101 June 17, 1998 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: Anderson-Tully Company Registration Statement on Form 10 File No. 0-24079 --------------------------------- Ladies and Gentlemen: Anderson-Tully Company (the "Company") hereby withdraws its previously filed Registration Statement on Form 10 (File No. 0-24079) relating to its common stock in order to avoid such Registration Statement becoming effective pursuant to Section 12(g)(1) of the Securities Exchange Act of 1934, as amended, prior to the completion of the review of such Registration Statement by the Staff of the Commission. The Company intends to refile the Registration Statement, revised to respond to the comments of the Staff contained in a letter dated June 15, 1998 received by the Company. Very truly yours, ANDERSON-TULLY COMPANY By: /s/ Marye Helen Owen -------------------- Marye Helen Owen General Counsel and Secretary cc: Robert T. Plesnarski, Esq. Thomas C. Janson, Jr. Ray Sandona