PROFFITT'S, INC. 750 Lakeshore Parkway Birmingham, AL 35211 Brian J. Martin Senior Vice President of Human Resources and Law General Counsel May 2, 1997 United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549 RE: G.R. Herberger's, Inc. 401(k) Employee Stock Purchase Plan and Employee Stock Ownership Plan The registrant, Proffitt's, Inc., has undertaken to submit the above referenced plan and any amendments thereto (the "Plan") to the Internal Revenue Service. The Registrant will make all changes required by the IRS in order to qualify the Plan under the Internal Revenue Code. Sincerely, By: /s/ Brian J. Martin --------------------------------- Brian J. Martin Executive Vice President of Law and General Counsel