<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>3
<FILENAME>totret.txt
<DESCRIPTION>AUDIT LETTER
<TEXT>
Report of Independent Accountants Auditors

To the Board of Directors and Shareholders of
Cohen & Steers Total Return Realty Fund, Inc.

In planning and performing our audit of the financial statements of
Cohen & Steers Total Return Realty Fund, Inc. (hereafter referred to
as the Fund) for the year ended December 31, 2003, we considered
its internal control, including control activities for safeguarding
securities, in order to determine our auditing procedures for the
purpose of expressing our opinion on the financial statements and to
comply with the requirements of Form N-SAR, not to provide assurance
on internal control.

The management of the Fund is responsible for establishing and
maintaining internal control.  In fulfilling this responsibility,
estimates and judgments by management are required to assess the
expected benefits and related costs of controls.  Generally, controls
that are relevant to an audit pertain to the entitys objective of
preparing financial statements for external purposes that are fairly
presented in conformity with generally accepted accounting principles.
Those controls include the safeguarding of assets against
unauthorized acquisition, use or disposition.

Because of inherent limitations in internal control, errors or fraud
may occur and not be detected.  Also, projection of any evaluation of
internal control to future periods is subject to the risk that controls
may become inadequate because of changes in conditions or that the
effectiveness of their design and operation may deteriorate.

Our consideration of internal control would not necessarily disclose
all matters in internal control that might be material weaknesses under
standards established by the American Institute of Certified Public
Accountants.  A material weakness is a condition in which the design or
operation of one or more of the internal control components does not
reduce to a relatively low level the risk that misstatements caused by
error or fraud in amounts that would be material in relation to the
financial statements being audited may occur and not be detected within
a timely period by employees in the normal course of performing their
assigned functions.  However, we noted no matters involving internal
control and its operation, including controls for safeguarding
securities, that we consider to be material weaknesses as defined
above as of December 31, 2003.

This report is intended solely for the information and use of the
Board of Directors, management and the Directors of the Fund and the
Securities and Exchange Commission and is not intended to be and should
not be used by anyone other than these specified parties.




PricewaterhouseCoopers LLP
New York, New York
February 17__, 2004
To the Board of Directors and Shareholders of
Cohen & Steers Total Return Realty Fund, Inc.







</TEXT>
</DOCUMENT>
