[GRAPHIC] 125 Broad Street New York, NY 10004-2498 TELEPHONE: 1-212-558-4000 FACSIMILE: 1-212-558-3588 ----------------- WWW.SULLCROM.COM LOS ANGELES . PALO ALTO . WASHINGTON, D.C. FRANKFURT . LONDON . PARIS BEIJING . HONG KONG . TOKYO MELBOURNE . SYDNEY February 3, 2006 Via E-mail Securities and Exchange Commission, 100 F Street, N.E., Washington, D.C. 20549. Re: Tri-Continental Corporation Ladies and Gentlemen: On behalf of Tri-Continental Corporation (the "Company"), we are pleased to file a preliminary proxy statement and forms of proxy (the "Proxy Materials") relating to the Company's upcoming annual meeting of stockholders to be held on May 4, 2006. The Company hopes to finalize the Proxy Materials and begin the printing and mailing process by February 13, 2006. As you will note, that date is currently indicated in the Proxy Materials as the date the Company intends to first mail. Please do not hesitate to contact either the undersigned at (212) 558-7383 or Donald R. Crawshaw at (212) 558-4016 with any questions that you may have. Sincerely, /s/ Nikola Uzelac ------------------------------ Nikola Uzelac (Attachments) cc: Frank J. Nasta (Tri-Continental Corporation) Donald R. Crawshaw (Sullivan & Cromwell LLP) Securities and Exchange Commission