[GILMAN + CIOCIA, INC. LETTERHEAD] January 18, 2006 Via Facsimile (202) 772-9205 Mr. Larry Spirgel United States Securities and Exchange Commission Mail Stop 3561 Washington, D.C. 20549 Re: Gilman + Ciocia, Inc. Comment Letter Dated January 10, 2006 Dear Mr. Spirgel: This is to confirm per my telephone conversation with Adam Washecka that the due date for Gilman + Ciocia, Inc.'s response to the above referenced letter has been extended to February 8, 2006. Sincerely, /s/ Christopher Kelly, Esq. Christopher Kelly, Esq. General Counsel CK:mak cc: Michael Ryan Dennis Conroy Carl Vogt Arthur Radin Laurie Cerveny February 8, 2006 Via Facsimile (202) 551-3375 United States Securities and Exchange Commission Washington, D.C. 20549 Re: Gilman + Ciocia, Inc. Comment Letter Dated January 10, 2006 Please find below our response to Question #2 of the staff's letter dated January 10, 2006. In light of our pending 10Q filing deadline we would like to call and discuss this item. Consolidated Statements of Operations, page 34 2. Explain to us the nature of your Salaries, Brokerage Fees and Licenses, Rent and Depreciation and Amortization line items and tell us your GAAP basis for not including them as part of Cost of Sales. Otherwise, please revise. The Staff is supplementally advised that the Company has included as Cost of Sales only its commission expense attributed to the revenues recorded, since commission expense is the single largest direct variable cost attributed to the sales recorded. Generally accepted accounting principles do not define which expenses to include or exclude from Cost of Sales. FASB Concepts Statement No. 3 - Elements of Financial Statements merely explains revenues and expenses. SEC Rule 210.5-03(b)2 discusses "Costs and expenses applicable to sales and revenues", with no clear definition of what is to be included in such cost category. Management of the Company determined that commission expense related to its revenues is the single best tool for determining the Company's profitability, and accordingly included in Cost of Sales commission expense only. The Company previously surveyed other public company filings and found a similar presentations of Cost of Sales. Alternatively, a majority of the public company filings of companies in similar industries to the Company followed the [AICPA Broker Dealer format, which not do have a classified statement of operations. This presentation, further supports there is no definitive rule as to which items to include in the Cost of Sales category. [The Company had filed its financial statements with the SEC using such presentation as suggested by the AICPA Broker Dealer guide through March 31, 2004. ] Sincerely, /s/ Dennis Conroy Dennis Conroy Chief Accounting Officer [GILMAN + CIOCIA, INC. LETTERHEAD] February 9, 2006 Via Facsimile (202) 772-9205 Mr. Larry Spirgel United States Securities and Exchange Commission Mail Stop 3561 Washington, D.C. 20549 Re: Gilman + Ciocia, Inc. Comment Letter Dated January 10, 2006 Dear Mr. Spirgel: This is to confirm per my telephone conversation with Adam Washecka that the due date for Gilman + Ciocia, Inc.'s response to the above referenced letter has been further extended to February 15, 2006. Sincerely, /s/ Dennis Conroy Dennis Conroy Chief Accounting Officer DC:mak cc: Michael Ryan Carl Vogt Arthur Radin Laurie Cerveny