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                   [LETTERHEAD OF SIMPSON THACHER & BARTLETT]

VIA EDGAR                                                      November 12, 2004

            Re: Cohen & Steers Quality Income Realty Fund, Inc.
                File Nos. 811-10481; 333-119361
                Filed on September 29, 2004

                Cohen & Steers Advantage Income Realty Fund, Inc.
                File Nos. 811-09993; 333-119488
                Filed on October 1, 2004

Keith A. O'Connell
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Dear Mr. O'Connell:

          On behalf of Cohen & Steers Quality Income Realty Fund, Inc.
("Quality") and Cohen & Steers Advantage Income Realty Fund, Inc. ("Advantage"
and, together with Quality, the "Funds"), we transmit for filing via EDGAR with
the Securities and Exchange Commission (the "Commission") the Pre-Effective
Amendments No. 1 (the "Amendments") to the Funds' initial registration
statements on Form N-2 (the "Registration Statements") to register additional
Taxable Auction Market Preferred Shares. The Registration Statement for Quality
was filed on September 29, 2004 and the Registration Statement for Advantage was
filed on October 1, 2004. By letter dated October 21, 2004, we were provided
with comments from the staff of the Commission (the "Staff") regarding the
Registration Statements. The purpose of these Amendments is to respond to the
Staff's comments to the Registration Statements that you provided in your letter
and to make certain other changes outlined below. In this regard, we note that
the Amendments are substantially similar to the Funds' original Registration
Statements except the Registration Statements now reflect the Merrill Lynch
trademark for auction rate preferred securities, "AMPS".

          Set forth below are the Funds' responses to your comments insofar as
they concern your inquiries that apply to the Funds.




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Keith A. O'Connell                                             November 12, 2004

Prospectus - Cohen & Steers Premium Income Realty Fund, Inc.

Federal Income Taxation, page 14

1. Page 15 states, "Such dividends generally will, except in the case of
distributions of qualified dividend income and net capital gains, be taxable as
ordinary income to holders." The Fund invests heavily in REITS. Please
prominently clarify whether the preferred dividends are generally expected to be
eligible to be treated as qualified dividend income.

     Response: Under the caption "Prospectus Summary - Federal Income Taxation"
in the Quality and Advantage Registration Statements and our discussion with
respect to the distributions of both Quality and Advantage, we have revised this
discussion to indicate that neither Quality nor Advantage expects a significant
portion of its distributions to be eligible for the dividends received deduction
or derived from qualified dividend income. This change was also made to the
Cohen & Steers Premium Income Realty Fund which was declared effective on
Wednesday, November 10, 2004.

Statement of Additional Information (SAI)

Investment Restrictions, page 4

2. Certain fundamental policies have been redlined. Supplementally, please
confirm that no fundamental policies have been changed without shareholder
approval.

     Response: The fundamental investment policies of the Funds have not been
changed and the text which was redlined in the previous filings has been revised
to conform identically to the fundamental investment policies in the prior
registration statements of Quality and Advantage that have been declared
effective.

Financial Highlights, page 48

3. Footnote d states "Total market value return is computed based upon the New
York Stock Exchange market price of the fund's shares and excludes the effects
of brokerage commissions." Supplementally, please explain what brokerage
commissions are being excluded.

     Response: Total market value is calculated on the basis of the beginning
and ending market price of shares of Quality and Advantage for the period
presented. In order for an investor to realize that return, the investor would
have to purchase the shares of either Quality or Advantage at the beginning of
the period. The purpose of that statement in footnote d is to point out that the
calculation excludes the effect of brokerage commissions that would be incurred
if an investor did buy the fund shares. In this regard, then, market value
return demonstrates the underlying changes in asset value without distortions
related to varying brokerage costs. We have included text in footnote "d" to
clarify this point.


                                       -2-




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Keith A. O'Connell                                             November 12, 2004

General

4. We note that portions of the filing are incomplete. We may have additional
comments on such portions when you complete them in a pre-effective amendment,
on disclosures made in response to this letter, on information supplied
supplementally, or on exhibits added in any pre-effective amendments.

     Response: With the exception of certain information that will be completed
in a final pre-effective filing with the Commission, the filings for Quality and
Advantage are now substantially complete. If comments given by the Staff in one
section apply to other sections containing similar disclosure, these comments
have also been addressed in the other sections.

5. If you intend to omit certain information from the form of prospectus
included with any registration statement that is declared effective in reliance
on Rule 430A under the Securities Act, please identify the omitted information
to us supplementally, preferably before filing the final pre-effective
amendment.

     Response: The Funds currently intend to rely on Rule 430A under the
Securities Act of 1933, as amended, and will identify the omitted information to
you prior to the final pre-effective amendments.

6. Please advise us if you have submitted or expect to submit an exemptive
application or no-action request in connection with your registration
statements.

     Response: Neither of the Funds expects to submit an exemptive application
or no-action request in connection with its registration.

          We trust that these responses and the Amendments adequately address
your comments. If you have any questions or additional concerns, of if you need
any additional information, please do not hesitate to contact Jon Gray at (212)
455-3205, or Larry Stoller, of Cohen & Steers.

                                             Very truly yours,


                                             /s/ Jon Gray
                                             -----------------------------------
                                             Jon Gray


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