<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>icletterrfi.txt
<DESCRIPTION>INTERNAL CONTROL LETTER
<TEXT>
Report of Independent Registered Public Accounting Firm
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. (the Company) as of and for the year ended
December 31, 2005, in accordance with the standards
of the Public Company Accounting Oversight Board
(United States), we considered the Company's
internal control over financial reporting, including
control activities for safeguarding securities, as
a basis for designing our auditing procedures for
the purpose of expressing our opinion on the financial
statements and to comply with the requirements of
Form N-SAR, but not for the purpose of expressing
an opinion on the effectiveness of the Company's
internal control over financial reporting.
Accordingly, we express no such opinion.
The management of the Company is responsible for
establishing and maintaining effective internal
control over financial reporting.  In fulfilling this
responsibility, estimates and judgments by management
are required to assess the expected benefits and
related costs of controls.  A company's internal
control over financial reporting is a process designed
to provide reasonable assurance regarding the
reliability of financial reporting and the preparation
of financial statements for external purposes in
accordance with generally accepted accounting
principles.  Such internal control over financial
reporting includes policies and procedures that
provide reasonable assurance regarding prevention or
timely detection of unauthorized acquisition, use or
disposition of a company's assets that could have a
material effect on the financial statements.
Because of its inherent limitations, internal control
over financial reporting may not prevent or detect
misstatements.  Also, projections of any evaluation of
effectiveness to future periods are subject to the
risk that controls may become inadequate because of
changes in conditions, or that the degree of
compliance with the policies or procedures may
deteriorate.
A control deficiency exists when the design or
operation of a control does not allow management or
employees, in the normal course of performing their
assigned functions, to prevent or detect misstatements
on a timely basis. A significant deficiency is a control
deficiency, or combination of control deficiencies,
that adversely affects the company's ability to
initiate, authorize, record, process or report external
financial data reliably in accordance with generally
accepted accounting principles such that there is more
than a remote likelihood that a misstatement of the
company's annual or interim financial statements that
is more than inconsequential will not be prevented or
detected.  A material weakness is a control deficiency,
or combination of control deficiencies, that results
in more than a remote likelihood that a material
misstatement of the annual or interim financial
statements will not be prevented or detected.
Our consideration of the Company's internal control
over financial reporting was for the limited purpose
described in the first paragraph and would not
necessarily disclose all deficiencies in internal
control over financial reporting that might be
significant deficiencies or material weaknesses under
standards established by the Public Company Accounting
Oversight Board (United States).  However, we noted
no deficiencies in the Company's internal control
over financial reporting and its operation, including
controls for safeguarding securities, that we consider
to be material weaknesses as defined above as of
December 31, 2005.
This report is intended solely for the information and
use of management and the Board of Directors of Cohen &
Steers Total Return Realty Fund, Inc. 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

February 17, 2006

</TEXT>
</DOCUMENT>
