HART & TRINEN, LLP
ATTORNEYS AT LAW
1624 Washington Street
Denver, CO 80203
William T. Hart, P.C. ________ Email:harttrinen@aol.com
Donald T. Trinen Facsimile:(303) 839-5414
(303) 839-0061
November 16, 2006
Scott Anderegg
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Re: Tian'an Pharmaceutical Co., Ltd.
Registration Statement on Form SB-2
File No. 333-135434
This office represents Tian'an Pharmaceutical Co., Ltd. (the "Company").
Amendment No. 4 to the Company's registration statement has been filed with the
Commission. This letter contains the Company's responses to the comments
received from the Staff by letter dated November 15, 2006. The paragraph numbers
in this letter correspond with the numbered paragraphs in the Staff's comment
letter.
Page Number
10, 11, 12
C-1 Comment complied with. 13 and 14
9/30/06
Financials
C-2 Comment complied with. The income expense for fiscal
2005 and 2004 has been revised. The income tax expense 12/31/05
for these periods (as revised) now reconciles with the Statement
percentages in Footnote 6. of
Operations
If you should have any questions concerning the foregoing, please do not
hesitate to contact the undersigned.
Very Truly Yours,
HART & TRINEN, L.L.P.
/s/ William T. Hart
William T. Hart
WTH:tg