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United States securities and exchange commission logo





                             March 16, 2023

       Stephen Bramlage, Jr.
       Chief Financial Officer
       Casey   s General Stores, Inc.
       One SE Convenience Blvd
       Ankeny, IA 50021

                                                        Re: Casey   s General
Stores, Inc.
                                                            Form 10-K for
Fiscal Year Ended April 30, 2022
                                                            Filed June 24, 2022
                                                            Response dated
March 3, 2023
                                                            File No. 001-34700

       Dear Stephen Bramlage:

              We have reviewed your March 3, 2023 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       February 10, 2023 letter.

       Form 10-K for Fiscal Year Ended April 30, 2022

       Management   s Discussion and Analysis of Financial Condition and
Results of Operations
       Liquidity and Capital Resources, page 25

   1.                                                   We note your response
to comment 1 and your proposed revised disclosure. We note
                                                        therein the references
to depreciation, amortization and deferred income taxes as factors
                                                        contributing to the
change in operating cash. Note these are noncash factors that do not
                                                        affect cash. In regard
to your disclosure in the Form 10-Q for the quarterly period
                                                        ended January 31, 2023,
we note the material change between periods in income taxes
                                                        presented in the
operating and supplemental sections of the statement of cash flows but
                                                        did not note inclusion
in your analysis of the impact of income taxes on operating cash
                                                        flows. Note the
requirement within Item 303(b) of Regulation S-K to describe the
 Stephen Bramlage, Jr.
Casey   s General Stores, Inc.
March 16, 2023
Page 2
         underlying reasons for material changes from period to period
reflected in the financial
         statements, including where material changes within a line item offset
one another. Please
         consider these items in your disclosures.
Notes to Consolidated Financial Statements
Note 1. Significant Accounting Policies
Inventories, page 38

2.       We note your proposed revisions in response to comment 3. Please
further expand your
         disclosure to discuss how you determine the value of RINs at the time
transferred and
         recorded in cost of goods sold.
       You may contact Patrick Kuhn at (202) 551-3308 or Doug Jones at (202)
551-3309 with
any questions.



FirstName LastNameStephen Bramlage, Jr.                      Sincerely,
Comapany NameCasey   s General Stores, Inc.
                                                             Division of
Corporation Finance
March 16, 2023 Page 2                                        Office of Trade &
Services
FirstName LastName
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