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February 10, 2006

Via EDGAR

Securities and Exchange Commission,
100 F Street, N.E.,
Washington, D.C. 20549.

Attention: Linda Stirling
Division of Investment Management

Re: Tri-Continental Corporation (File
No. 811-00266)
Preliminary Proxy Statement

Dear Ms. Stirling:

This letter provides a response to your comment on the preliminary proxy
statement of Tri-Continental Corporation (the "Corporation") filed on February
3, 2006, which you provided telephonically to the undersigned on February 9,
2006. Your comment was to provide disclosure in the proxy statement regarding
any person known to the Corporation to be the holder of more than 5% of the
Corporation's voting securities. In response to your comment, we have revised
the preliminary proxy statement to include such information under the
subheading "Security Ownership of Certain Beneficial Owners" and attach hereto
the relevant page from the Corporation's revised proxy statement.

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

(Attachment)

cc: Frank J. Nasta
(Tri-Continental Corporation)
Donald R. Crawshaw, Esq.
(Sullivan & Cromwell LLP)

Dollar Range of Common Aggregate Dollar Range of Shares Owned
Shares Owned by Director by Director or Nominee of All Funds
or Nominee of the Overseen or to be Overseen by Director
Name of Director/Nominee Corporation or Nominee of Seligman Group of Funds
- ------------------------ ------------------------ --------------------------------------

Interested
Directors/Nominee
William C. Morris Over $100,000 Over $100,000
Brian T. Zino Over $100,000 Over $100,000

As of February 1, 2006, all Directors and officers of the Corporation as a
group owned beneficially less than 1% of the Corporation's Common Stock and
less than 1% of the Corporation's Preferred Stock.

Section 16(a) Beneficial Ownership Reporting Compliance

During the year ended December 31, 2005, one transaction in the
Corporation's Common Stock by David F. Stein (Vice Chairman of the Manager),
two transactions in the Corporation's Common Stock by Frank J. Nasta (the
Secretary of the Corporation) and four transactions in the Corporation's Common
Stock by Michael F. McGarry (a Vice President and Co-Portfolio Manager of the
Corporation) were not reported within two business days as required. The
necessary filings for each Stockholder were subsequently made.

Security Ownership of Certain Beneficial Owners

The table below sets forth the beneficial ownership as of February 1, 2006
of each person (including any "group" as that term is used in Section 13(d)(3)
of the Securities Exchange Act of 1934, as amended) known by the Corporation to
be the beneficial owner of more than 5% of the outstanding shares of any class
of the Corporation's stock.

Name of Beneficial Owner Number of Shares Beneficially Owned Percent of Class
------------------------ ----------------------------------- ----------------

A group led by Western Investment 7,281,741 shares of Common 6.77%
LLC and including 13 other Stock
members/1/

- -----------------
/1/ Information regarding group membership and shareholdings was obtained from
the Schedule 14A filed jointly on February 10, 2006 and the Schedule 13D/A
filed jointly as a group on January 10, 2006 by Western Investment LLC,
Arthur D. Lipson, Western Investment Hedged Partners L.P., Western
Investment Activism Partners LLC, Benchmark Plus Institutional Partners,
L.L.C., Benchmark Plus Partners, L.L.C., Benchmark Plus Management,
L.L.C., Paradigm Partners, N.W., Inc., Scott Franzblau, Robert Ferguson,
Michael Dunmire, Matthew S. Crouse, Paul Derosa and Marlene A. Plumlee.