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<SEC-DOCUMENT>0000000000-05-057109.txt : 20060905
<SEC-HEADER>0000000000-05-057109.hdr.sgml : 20060904
<ACCEPTANCE-DATETIME>20051110101022
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-05-057109
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20051110

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			GAS TRANSPORTER OF THE SOUTH INC
		CENTRAL INDEX KEY:			0000931427
		STANDARD INDUSTRIAL CLASSIFICATION:	NATURAL GAS TRANSMISSION [4922]
		IRS NUMBER:				000000000
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		DON BOSCO 3672 5TH FLR
		STREET 2:		1206 CAPITAL FEDERAL
		CITY:			ARGENTINA
		STATE:			C1
		ZIP:			00000
		BUSINESS PHONE:		005401148659050X1093

	MAIL ADDRESS:	
		STREET 1:		DON BOSCO 3672 5TH FLR
		STREET 2:		CAPITAL FEDERAL
		CITY:			ARGENTINA
		STATE:			C1
		ZIP:			1206
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0308

         DIVISION OF
CORPORATION FINANCE


Mail Stop 03-08

September 21, 2005

Eduardo Pawluszek
Chief Financial Officer
Gas Transporter of the South
Don Bosco 3672
5th Floor
C1206ABF Buenos Aires, Argentina

	Re: 	Gas Transporter of the South
		Form 20-F for the Fiscal Year Ended December 31, 2004
Forms 6-K for the Fiscal Quarters Ended June 30, 2005 and March
31,
2005
		File No.  1-13396

Dear Mr. Pawluszek,

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.  Where
indicated, we think you should revise your documents in response
to
these comments in future filings.  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 information so we may better understand your disclosure.
After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 20-F for the Year Ended December 31, 2004

Item 18.  Financial Statements, page F-1

Note 3.  Consolidated Business Segment Information, page F-12

1. In future filings, please disclose in the note reconciling
differences between US GAAP and Argentinean GAAP interest revenue
and
interest expense for each reportable segment as required by
paragraph
27 (c) and (d) of FAS 131 for the periods presented.

Note 12.  Differences Between Argentine GAAP and US GAAP, page F-
24

2. Please tell us how interest costs qualify for capitalization in
accordance with paragraphs 9 and 10 of FAS 34.  In addition,
please
include the disclosure requirements of paragraph 21 (a) and (b) of
FAS 34 in future filings.

3. It appears that you carry investment securities that fall under
the scope of Statements of Financial Accounting Standards No. 115,
"Accounting for Certain Investments in Debt and Equity Securities"
("FAS 115") under U.S. GAAP.  In future filings, for each
investment
type, please disclose if these investments are held-to-maturity,
trading, or available-for-sale, if there is a difference in the
way
you account for these investments under Argentine GAAP as compared
to
US GAAP, and make all the necessary disclosures as required by
paragraph 19 of FAS 115.

4. In future filings, please present a statement of comprehensive
income for all periods presented.

5. Please tell us how you considered Statement of Financial
Accounting Standards No. 71, "Accounting for the Effects of
Certain
Types of Regulation" ("SFAS 71") regarding your regulated gas
transportation and distribution operations.  Specifically refer to
each of the criterion in paragraph 5 (a) - (c).

6. U.S. GAAP requires separate presentation of shareholders`
equity
components on the face of the balance sheet.  Please include the
following as a reconciling item in future filings:
* For each class of common shares state the number of shares
issued
or outstanding, as appropriate, and the dollar amount thereof; See
Rule 5-02.30 of Regulation S-X;
* For other shareholders` equity items, separate captions shall be
shown for:  (1) additional paid in capital, (2) other additional
capital, and (3) retained earnings.  See Rule 5-02.31 of
Regulation
S-X.

*	*	*	*

      Please send us your response to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter keying your responses to our
comments
and provide any requested supplemental information.  Please file
your
response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a 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;
* 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 Dave Irving, Staff Accountant, at (202) 551-
3321 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3841
with any other questions.

Sincerely,



Michael Moran
Branch Chief
??

??

??

??

Mr. Eduardo Pawluszek
Gas Transporter of the South
September 21, 2005
Page 3 of 3


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