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United States securities and exchange commission logo





                              February 26, 2024

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

                                                        Re: Casey   s General
Stores, Inc.
                                                            Form 10-K for
Fiscal Year Ended April 30, 2023
                                                            File No. 001-34700

       Dear Stephen Bramlage:

                                                        We have reviewed your
filing and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for Fiscal Year Ended April 30, 2023

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Fiscal 2023 Compared with Fiscal 2022, page 21

   1.                                                   Where you identify
multiple factors which contributed to material changes in your period
                                                        over period results,
please expand your disclosures to quantify the individual impact of
                                                        each factor. As an
example, your non-fuel revenues were impacted by operating
                                                        more stores than a year
ago, strategic retail price adjustments, and strong or increased
                                                        sales without providing
quantification of the individual factors cited to allow users to
                                                        understand the
magnitude and relative impact of each factor. Additionally, to the extent
                                                        you can quantify the
impact inflation has had on your pricing and cost of good sold, please
                                                        revise to provide such
quantification. Refer to Item 303 of Regulation S-K and section
                                                        III.D of Release No.
33-6835.
       Liquidity and Capital Resources, page 25

   2.                                                   In your analysis of
changes in reported operating cash flows you refer to the impact of
                                                        deferred taxes. It
appears deferred taxes are a noncash item that do not directly impact
                                                        cash of operating
activities. You also refer to the change in income tax balances as a factor
 Stephen Bramlage, Jr.
Casey   s General Stores, Inc.
February 26, 2024
Page 2
         for the increase in operating activities in 2023 compared to 2022.
However, the
         supplemental disclosures of cash flows information reports cash paid
for income taxes
         was a greater direct use of operating cash in 2023 compared to 2022 in
contradiction to
         what the change in income tax balances indicates. Substituting this
direct use of cash for
         income taxes paid for the indirect change in income tax balances
appears to impact the
         overall analysis of material factors contributing to changes in
operating activities between
         periods. Please note reference to reconciling items presented in the
statement of cash
         flows in deriving reported operating cash flows for a period may not
necessarily provide a
         sufficient basis to understand how actual operating cash was directly
affected between
         periods. Refer to the introductory paragraph of section IV.B and B.1
of Release No. 33-
         8350 for guidance on the analysis of operating cash flows and
incorporate it in your
         analysis as appropriate.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Abe Friedman at 202-551-8298 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters.



FirstName LastNameStephen Bramlage, Jr.                        Sincerely,
Comapany NameCasey   s General Stores, Inc.
                                                               Division of
Corporation Finance
February 26, 2024 Page 2                                       Office of Trade
& Services
FirstName LastName
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