April 22, 2005

via facsimile and U.S. mail
Richard B. Abshire.
Chief Financial Officer
4400 Post Oak Parkway Ste. 2700
Houston, Texas 77027

	Re:	Adams Resources & Energy, Inc.
		Form 10-K, for the year ended December 31, 2004
      File No. 1-7908


Dear: Mr. Richard B. Abshire,

      We have reviewed the above filing and have the following
accounting comments.  We have limited our review to only the
matters
addressed below and will make no further review of your document.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


10-K for the year ended December 31, 2004

Financial Statements

Note 1 - Significant Accounting Policies, page 16

      Property and Equipment

1. We note your capitalization policy stating that exploratory
drilling costs are capitalized "...until the properties are
evaluated
and determined to be either productive or nonproductive."  Please
expand your disclosures to include total suspended drilling costs,
as
of each balance sheet date, and the amount of such costs that are
associated with (i) wells in areas requiring a major capital
expenditure before production could begin, where additional
drilling
efforts are not underway or firmly planned for the near future,
and
(ii) wells in areas not requiring a major capital expenditure
before
production could begin, where more than one year has elapsed since
the completion of drilling.

To the extent you have material suspended well costs, please
provide
corresponding disclosures explaining why the delay in
characterizing
your reserves as proved reserves was unavoidable; include the
dates
that your exploratory drilling efforts were completed.  Your
disclosures should convey the status of the significant properties
or
projects involved, including the anticipated timing of when you
expect to be able to determine whether or not proved reserves have
been found.  Refer to the February 11, 2005 Industry Letter on our
website at
www.sec.gov/divisions/corpfin/guidance/oilgas021105.htm,
and the guidance in FSP FAS 19-1, for further clarification.


Note 11 - Marketing Joint Venture, page 22

2. We note your disclosure describing your settlement with your
former co-venture partner, Williams-Gulfmark Energy, resulting in
the
gain of $1,476,000 that you indicate was recorded as an offset to
cost of sales.  We understand that you received accounts
receivable
of the joint venture as part of the arrangement, although you were
also required to pay $350,000 and assume all future obligations of
the joint venture.

Please expand your disclosure to quantify the amounts assigned to
each element of your arrangement.  It should be clear how you were
able to realize a gain on settlement of what would seemingly have
been an additional cost, based on the claim you described.  Also,
since you have no account labeled cost of sales on page 13,
replace
your reference to cost of sales with the line item reflecting the
adjustment identified.

Finally, tell us how you determined it was appropriate to
recognize a
gain in the fourth quarter of 2004, rather than restate your
financial results of prior periods, given your disclosure
indicating
the disputed amount of $11.6 million related to activity for the
period from May 2000 through October 2001.


Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
amendments to expedite our review.  Please furnish a cover letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filing(s);

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filing; and

	the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Jon Duersch at (202) 942-1761 or Karl Hiller
at
(202) 942-1981 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
942-1870 with any other questions.  Direct all correspondence to
the
following ZIP code:  20549-0405.

							Sincerely,



							H. Roger Schwall
							Assistant Director
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Adams Resources & Energy, Inc.
April 22, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE