EXHIBIT 15



                           ACCOUNTANT'S ACKNOWLEDGMENT


We  acknowledge the incorporation by reference in the Registration Statements on
Form  S-3 (filed in October 2000 and March 2001) and Form S-8 (filed in November
1997)  of  Penn  Octane  Corporation  of our report dated December 6, 2002 which
appears  on  page  3  of the Quarterly Report on Form 10-Q for the quarter ended
October  31,  2002.


                                    /s/  BURTON MCCUMBER & CORTEZ, L.L.P.


Brownsville, Texas
December 6, 2002



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