Bulldog Investors General Partnership,
60 Heritage Drive,
Pleasantville, NY 10570
(914) 747-5262 // Fax: (914) 747-2150 //
pgoldstein@bulldoginvestors.com

			May 19, 2009


Mr. Brion R. Thompson
Senior Counsel
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Insured Municipal Income Fund Inc. (the "Fund")

Dear Mr. Thompson:

We are responding to your comments about the PREC14A filing we made on
April 29, 2009.

We are filing an amended preliminary proxy statement and form of proxy
that incorporates information contained in management's PRE 14A filing
made on May 15, 2009.  In addition, please note the following:

..	We do not intend to send our definitive proxy material until
        management has filed its definitive proxy material.  If we change
        our mind, we will advise you before we do so.

..	We provided the additional information you asked for about the
        Massachusetts litigation.

..	We included the nature of the businesses with which our nominees
        are affiliated.

Finally, we acknowledge that the staff takes the position that we may not
use its comments in a defense of an enforcement action.  However we
respectfully decline to waive our right to do so because that might
compromise our ability to present a zealous defense.

If you have any further questions or comments, please call me at 914-747-5262.

        					Very truly yours,


						Phillip Goldstein
						Managing Member
						Kimball & Winthrop, Inc.
							General Partner