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77B Accountant's Report on Internal Control
[PricewaterhouseCoopers logo]
PricewaterhouseCoopers LLP
160 Federal Street
Boston, MA 02110-9862
                           Report of Independent Accountants

To the Trustees and the Shareholders of
Colonial High Income Municipal Trust

In planning and  performing  our audit of the  financial  statements of Colonial
High Income  Municipal  Trust (the "Fund") for the year ended November 30, 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,  and 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
entity's 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 it may become  inadequate  because of
changes in conditions or that the  effectiveness of the 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
November 30, 2003.

This  report is  intended  solely  for the  information  and use of the Board of
Trustees,  management  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
January 12, 2004



77O Transactions effected pursuant to Rule 10f-3

On July 10, 2003, Colonial High Income Municipal Trust (Fund) purchased
$300,000 par value of bonds of Massachusetts Health and Educational Facilities
- Jordan Hospital, Series E - 6.75% 10/01/33 (Securities) for a total purchase
price of $297,000 from Morgan Stanley/Lattice pursuant to a public offering
in which Quick & Reilly, Inc. acted as a participating underwriter. Quick &
Reilly, Inc. may be considered to be an affiliate of the Fund.

The following information was collected pursuant to Rule 10f-3 procedures
adopted by the Fund's Trustees:

o        The Fund's advisor, Columbia Management Advisors, Inc. believed that
         the gross underwriting spread associated with the purchase of the
         Securities was reasonable and fair compared to the spreads in
         connection with similar underwritings of similar securities being sold
         during a comparable period of time;

o        The Securities were offered pursuant to an underwriting or similar
         agreement under which the underwriters were committed to purchase all
         of the Securities being offered;

o        The issuer of the Securities has been in continuous operation for at
         least three years;

o        The amount of Securities purchased did not exceed 25% of the amount
         of the offering;

o        The Securities were to be purchased at not more than the public
         offering price no later than the first day of the offering.

Along  with Quick & Reilly, Inc.,  the following is a list of members of the
underwriting  syndicate for the aforementioned Securities: Advest, Inc.; Morgan
Stanley.


On July 10, 2003, Colonial High Income Municipal Trust (Fund) purchased
$200,000 par value of bonds of Massachusetts Health and Educational Facilities
- Jordan Hospital, Series E - 6.75% 10/01/33 (Securities) for a total purchase
price of $198,000 from Advest, Inc. pursuant to a public offering
in which Quick & Reilly, Inc. acted as a participating underwriter. Quick &
Reilly, Inc. may be considered to be an affiliate of the Fund.

The following information was collected pursuant to Rule 10f-3 procedures
adopted by the Fund's Trustees:

o        The Fund's advisor, Columbia Management Advisors, Inc. believed that
         the gross underwriting spread associated with the purchase of the
         Securities was reasonable and fair compared to the spreads in
         connection with similar underwritings of similar securities being sold
         during a comparable period of time;

o        The Securities were offered pursuant to an underwriting or similar
         agreement under which the underwriters were committed to purchase all
         of the Securities being offered;

o        The issuer of the Securities has been in continuous operation for at
         least three years;

o        The amount of Securities purchased did not exceed 25% of the amount
         of the offering;

o        The Securities were to be purchased at not more than the public
         offering price no later than the first day of the offering.

Along  with Quick & Reilly, Inc.,  the following is a list of members of the
underwriting  syndicate for the aforementioned Securities: Advest, Inc.; Morgan
Stanley.


77Q2
Section 16(a) Beneficial Ownership Reporting Compliance

For each of the following persons, who are subject to Section 16 of the Exchange
Act of 1934, as amended (the "Exchange Act"), with respect to the registrant
because of the requirements of Section 30 of the Investment Company Act of 1940,
a Form 3 report, which is required by Section 16(a) of the Exchange Act, was not
filed on a timely basis.

Patrick J. Simpson   (no holdings)
Richard L. Woolworth  (no holdings)

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