<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>icletterrfi.txt
<DESCRIPTION>AUDITOR'S 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, 2006, 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 on the effectiveness of the Company's internal
control over financial reporting.

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, 2006.

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 16, 2007




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</DOCUMENT>
