February 24, 2006 Mail Stop 4561 Mr. George N. Tietjen III Chief Financial Officer and Treasurer SB Partners 1251 Avenue of the Americas New York, NY 10020 	RE:	SB Partners Form 10-K for the fiscal year ended December 31, 2004 		Filed April 13, 2005 		Form 10-Q for the quarterly period ended March 31, 2004 		File No. 0-08952 Dear Mr. Tietjen: We have completed our review of your Form 10-K and related filings and do not, at this time, have any further comments. 							Sincerely, Daniel L. Gordon Branch Chief ?? ?? ?? ??