THE O'NEAL LAW FIRM, P.C.
                            17100 East Shea Boulevard
                                   Suite 400-D
                          Fountain Hills, Arizona 85268
                              (480) 812-5058 (Tel)
                              (480) 816-9241 (Fax)


                                  March 8, 2006

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

Re: Tank Sports, Inc.
    Registration Statement on Form SB-2
    File No.  333-129910
    Filed February 9, 2006

Dear Mr. Owings:

We are writing in response to your  comment  letter  dated  February 28, 2006 in
connection with the above-referenced filing.

General
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Comment #1: We note your response to prior comment 17 in which we requested that
you  file  your  agreements  with  contract  manufacturers  as  exhibits  to the
registration  statement. In your response, you indicated that these arrangements
are governed by purchase orders and not by contracts.  However,  it is clear the
purchase  orders are  material to the  business.  Accordingly,  in the  Business
section  you should  include a summary of the terms of the  purchase  orders and
business arrangements relating to manufacturing your products.

Response:  In the third paragraph of the subsection  entitled  "Current Business
Operations" we have included terms of the standard format purchase order used by
the company when placing its product orders.

Comment #2: We note your  response to prior comment 27 and your  description  of
the Steady  Star loan,  which  matured in April of 2002.  In this  section,  you
should  disclose  the current  state of the loan as it appears  that it has been
extended. Please describe the maturity terms in this section.

Response:  We have revised and  clarified  this  disclosure to disclose that the
loan had been paid in full as of July 21, 2002.

Comment #3: We note that your fiscal year ends in the next few days. When you
file your next amendment, you will need to provide executive compensation
information in the table for 2006.

Response:  We have  included  compensation  information  for  fiscal  2005 ended
February 28,2006 in the Executive Compensation Table.



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Financial Statements
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Notes to Financial Statements
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Note 2. Summary of Significant Accounting Policies, page 46
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Comment #4: Please refer to prior comment 32. Please remove the previously noted
contradiction  from your revenue  recognition  accounting policy and include the
basis for the title  transfer as described in your  response to comment 34. This
disclosure  should be consistent  with your proposed new  disclosure in critical
accounting policies.

Response:  Noted. We have removed the previously  noted  contradiction  from our
revenue  recognition  accounting  policy  and  include  the  basis for the title
transfer as described in our response to prior comment 34.

Please do not hesitate to contact us if you have any further questions.

Very truly yours,



/s /William D. O'Neal
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/s/ William D. O'Neal

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