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<TYPE>EX-99.77B ACCT LTTR
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<FILENAME>pxztr77b.txt
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PricewaterhouseCoopers LLP
125 High Street
Boston, MA 02110-1707
Telephone (617) 530 5000
Facsimile (617) 530 5001
www.pwc.com


 Report of Independent Registered Public Accounting Firm


To the Board of Directors and Shareholders of The Zweig Total
Return Fund, Inc.

In planning and performing our audit of the financial
statements of The Zweig Total Return Fund, Inc. (the "Fund") as
of and for the year ended December 31, 2007, in accordance with
the standards of the Public Company Accounting Oversight Board
(United States), we considered the Fund'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 Fund's internal control over financial
reporting. Accordingly, we do not express an opinion on the
effectiveness of the Company's internal control over financial
reporting.

The management of the Fund 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.  The Funds' internal control over
financial reporting includes those policies and procedures that
(1) pertain to the maintenance of records that, in reasonable
detail, accurately and fairly reflect the transactions and
dispositions of the assets of the Funds; (2) provide reasonable
assurance that transactions are recorded as necessary to permit
preparation of financial statements in accordance with
generally accepted accounting principles, and that receipts and
expenditures of the Funds are being made only in accordance
with authorizations of management and directors of the Funds;
and (3)  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 deficiency in internal control over financial reporting
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 material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a
material misstatement of the Company's annual or interim
financial statements will not be prevented or detected on a
timely basis.

Our consideration of the Fund'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
Fund's internal control over financial reporting and its
operation, including controls for safeguarding securities, that
we consider to be a material weakness as defined above as of
December 31, 2007.

This report is intended solely for the information and use of
management and the Board of Directors of The Zweig Total Return
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 15, 2008

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