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		PO Box 4333
		Houston, TX 77210-4333
		11 Greenway Plaza, Suite 2500
		Houston, TX 77046
		713 626 1919
		www.invesco.com

May 15, 2012

VIA EDGAR

Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549


Re:		Invesco Value Municipal Income Trust CIK No. 0000885601, File No. 333-180582

Ladies and Gentlemen:

On behalf of Invesco Value Municipal Income Trust (the “Trust”), attached herewith for filing pursuant to the provisions of the Securities Act of 1933, as amended, is the electronic version of the Trust’s Pre-Effective Amendment No. 1 (the “Amendment”) to its registration statement on Form N-14 (the “Registration Statement”) containing a joint proxy statement/prospectus filed to register the following:

•

Common shares of beneficial interest of the Trust that will be issued to the holders of common shares of beneficial interest of Invesco Value Municipal Bond Trust, Invesco Value Municipal Securities and Invesco Value Municipal Trust.

The Amendment is being filed to update certain financial information and to make certain changes, including responding to disclosure comments from the staff of the Securities and Exchange Commission. We anticipate requesting that the Registration Statement be declared effective by June 1, 2012.

Please send copies of all correspondence with respect to the Registration Statement to my attention or contact me at 713.214.1968.

Very truly yours,


	/s/ Stephen R. Rimes
	Stephen R. Rimes
	Counsel