EXHIBIT 16

                       {DELOITTE & TOUCHE LLP LETTERHEAD]

December 8, 1998

Securities and Exchange Commission
Mail Stop 9-5
450 5th Street, N.W.
Washington, D.C.  20549

Dear Sirs/Madams:

We have  read Item 4 of Form 8-K of ILX  Resorts  Incorporated  (the  "Company")
dated November 20, 1998 and have the following comments.

We agree  with the  comments  in the first  and  second  sentences  of the first
paragraph,  the third paragraph and the first sentence of the fourth  paragraph.
We have no basis to agree or disagree with the comments in the third sentence of
the first  paragraph,  the second sentence of the fourth paragraph and the fifth
paragraph.

With  respect to the  disagreement  between the  Company  and  Deloitte & Touche
("D&T") and related matters discussed in the second  paragraph,  on November 20,
1998,  we advised the Audit  Committee  of the Board of Directors of the Company
(the "Audit Committee") of the following.

On  September  29,  1998,  the Company  entered  into an  agreement  to prepay a
promissory note payable to Martori Enterprises  Incorporated ("MEI") in exchange
for the  forgiveness  of $200,000 of the principal  amount of the note. MEI is a
related party which owns  approximately 22 percent of the Company's  outstanding
common stock and whose Chairman of the Board of Directors (Joseph P. Martori) is
also the Chairman of the Company's  Board of Directors  and the Company's  Chief
Executive  Officer.  On November 11, 1998, D&T received from the Company a draft
of the Company's  consolidated  financial statements as of and for the three and
nine months ended September 30, 1998 (the "9/30/98 Financial Statements"), which
recorded the $200,000 debt  forgiveness as interest  income.  Over the period of
November 12 and 13, 1998,  and prior to the Company filing its Form 10-Q for the
quarter ended  September  30, 1998 (the  "9/30/98  Form 10-Q"),  D&T advised the
Company's Chief Financial Officer, its Chairman and Chief Executive Officer, its
President, and one of the two members of its Audit Committee,  that: (i) because
of the nature of the related party  transaction,  D&T believed that the $200,000
debt forgiveness  should be recorded as a credit to additional  paid-in capital;
and (ii) because the 9/30/98  Financial  Statements  included the $200,000  debt
forgiveness as interest income,  D&T believed the 9/30/98  Financial  Statements
were misstated,  and that those financial statements needed to be adjusted prior
to the Company's filing its Form 10-Q.  Certain of this  information,  including
the existence of a disagreement  between D&T and the Company's  management,  was
discussed with the second member of the Audit  Committee  prior to the Company's
filing the  9/30/98  Form 10-Q.  The  Company  disagreed  with D&T's  conclusion
regarding the accounting treatment for the debt forgiveness and, on November 13,
1998,  filed the 9/30/98 Form 10-Q containing the 9/30/98  Financial  Statements
without  making  the  adjustment  proposed  by D&T (as  discussed  above) to the
financial statements for the $200,000 debt forgiveness.

Yours Truly,

/s/  Deloitte & Touche

                                  Page 5 of 5