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Proc-Type: 2001,MIC-CLEAR
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<SEC-DOCUMENT>0001144204-04-013525.txt : 20050512
<SEC-HEADER>0001144204-04-013525.hdr.sgml : 20050512

<ACCEPTANCE-DATETIME>20040830163901

<PRIVATE-TO-PUBLIC>

ACCESSION NUMBER:		0001144204-04-013525

CONFORMED SUBMISSION TYPE:	8-K

PUBLIC DOCUMENT COUNT:		3

CONFORMED PERIOD OF REPORT:	20040819

ITEM INFORMATION:		Changes in Registrant.s Certifying Accountant

ITEM INFORMATION:		Financial Statements and Exhibits

FILED AS OF DATE:		20040830

DATE AS OF CHANGE:		20040902


FILER:


	COMPANY DATA:	

		COMPANY CONFORMED NAME:			AMARILLO BIOSCIENCES INC

		CENTRAL INDEX KEY:			0001014763

		STANDARD INDUSTRIAL CLASSIFICATION:	PHARMACEUTICAL PREPARATIONS [2834]

		IRS NUMBER:				751974352

		STATE OF INCORPORATION:			TX

		FISCAL YEAR END:			1231



	FILING VALUES:

		FORM TYPE:		8-K

		SEC ACT:		1934 Act

		SEC FILE NUMBER:	333-04413

		FILM NUMBER:		041005759



	BUSINESS ADDRESS:	

		STREET 1:		800 W 9TH AVE

		CITY:			AMARILLO

		STATE:			TX

		ZIP:			79101-3206

		BUSINESS PHONE:		8063761741



	MAIL ADDRESS:	

		STREET 1:		AMARILLO BIOSCIENCES INC

		STREET 2:		800 W 9TH AVE

		CITY:			AMARILLO

		STATE:			TX

		ZIP:			79101-3206



</SEC-HEADER>

<DOCUMENT>
<TYPE>8-K
<SEQUENCE>1
<FILENAME>v06382.txt
<TEXT>
                    CURRENT REPORT FOR ISSUERS SUBJECT TO THE
                         1934 ACT REPORTING REQUIREMENTS

                                    FORM 8-K

                       SECURITIES AND EXCHANGE COMMISSION
                              Washington, DC 20549

                                 CURRENT REPORT

         Pursuant to Section 13 or 15(d) of the Securities Exchange Act

                                 August 19, 2004
                                 Date of Report
                        (Date of Earliest Event Reported)

                           Amarillo Biosciences, Inc.
             (Exact name of registrant as specified in its charter)

          Texas                     0-20791                     75-1974352
(State or other jurisdiction    (Commission File Number)      (IRS Employer
 of incorporation)                                          Identification No.)

                            4134 BUSINESS PARK DRIVE
                           AMARILLO, TEXAS 79110-4225
               (Address of principal executive offices (zip code)

                                 (806) 376-1741
              (Registrant's telephone number, including area code)


ITEM  4.  CHANGE IN REGISTRANT'S CERTIFYING ACCOUNTANT

Malone & Bailey, PLLC (the "Former Accountant") was dismissed on August 19, 2004
as Amarillo Biosciences,  Inc.'s independent  auditors.  Malone & Bailey's audit
reports as of December  31, 2003 and 2002 and for the two years then on Amarillo
Biosciences, Inc.'s consolidated financial statements did not contain an adverse
opinion or  disclaimer  of  opinion,  or  qualification  or  modification  as to
uncertainty,  audit  scope,  or  accounting  principles,  except that the report
indicated that the Company has suffered  recurring  losses and its need to raise
additional capital that raise substantial doubt about its ability to continue as
a going concern.

During the two most recent fiscal years ended  December 31, 2003 and 2002 and in
the  subsequent  interim  periods  through the date of dismissal,  there were no
disagreements with Malone & Bailey, PLLC on any matters of accounting principles
or practices,  financial statement disclosure,  or auditing scope and procedures
which,  if not resolved to the  satisfaction  of Malone & Bailey PLLC would have
caused  Malone & Bailey,  PLLC to make  reference to the matter in their report.
Amarillo  Biosciences,  Inc. has requested Malone & Bailey, PLLC to furnish it a
letter  addressed  to the  Commission  stating  whether it agrees with the above
statements.  A copy of that letter, dated August 19, 2004 is filed as Exhibit 16
to this Form 8-K.  Lopez,  Blevins,  Bork &  Associates,  L.L.P.  was engaged on
August 19, 2004 as Amarillo  Biosciences,  Inc.'s principal  accountant to audit
the financial  statements of Amarillo  Biosciences,  Inc. The decision to change
accountants was approved by the Board of Directors.

During the years ended December 31, 2003 and 2002 and subsequent to December 31,
2003 through the date hereof,  neither Amarillo Biosciences,  Inc. nor anyone on
its behalf consulted with Lopez,  Blevins, Bork & Associates,  L.L.P.  regarding
either the  application  of accounting  principles  to a specified  transaction,
either  completed  or  proposed,  or the type of  audit  opinion  that  might be
rendered on Amarillo Biosciences,  Inc.'s consolidated financial statements, nor
has Lopez, Blevins, Bork & Associates,  L.L.P. provided to Amarillo Biosciences,
Inc. a written report or oral advice  regarding such principles or audit opinion
or any matter that was the subject of a  disagreement  or reportable  events set
forth in Item 304(a)(iv) and (v), respectively, of Regulation S-K.

<PAGE>

Amarillo  Biosciences,  Inc. has requested  Lopez,  Blevins,  Bork & Associates,
L.L.P.  review the  disclosure  in this report on Form 8-K and  provided  Lopez,
Blevins,  Bork  &  Associates,   L.L.P.  the  opportunity  to  furnish  Amarillo
Biosciences,  Inc. with a letter addressed to the Commission  containing any new
information,  clarification of Amarillo  Biosciences,  Inc.'s  expression of its
views, or the respects in which Lopez, Blevins,  Bork & Associates,  L.L.P. does
not agree with the statements made by Amarillo Biosciences, Inc. in this report.
Lopez, Blevins, Bork & Associates, L.L.P. has advised Amarillo Biosciences, Inc.
that no such letter need be issued.


ITEM  7. FINANCIAL STATEMENTS, PRO FORMA FINANCIAL INFORMATION AND EXHIBITS


(c) EXHIBITS

16.1  Letter  from  Malone  &  Bailey,   PLLC  regarding  change  in  certifying
accountant.


SIGNATURES

Pursuant  to the  requirements  of the  Securities  Exchange  Act of  1934,  the
Registrant  has duly caused this Current  Report on Form 8-K to be signed on its
behalf by the undersigned hereunto duly authorized.

Amarillo Biosciences, Inc.


By: /s/ Joseph M. Cummins
    --------------------------
    Joseph M. Cummins
    Chief Executive Office


Dated:  August 19, 2004





</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>EX-16.1
<SEQUENCE>2
<FILENAME>v06382_16-1.txt
<TEXT>
Exhibit 16.1


August 19, 2004

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:      Amarillo Biosciences, Inc.
         Commission File Number 0-20791

We have read the statements that we understand Amarillo Biosciences, Inc. will
include under Item 4 of the Form 8-K report it will file regarding the recent
change of auditors. We agree with such statements made regarding our firm. We
have no basis to agree or disagree with other statements made under Item 4.


Very truly yours,

/s/ Malone & Bailey, PLLC
- -------------------------
Malone & Bailey, PLLC


</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>3
<FILENAME>v06382_corresp.txt
<TEXT>

Mr. Oscar M. Young Jr.
U.S. Securities and Exchange Commission
450 Fifth St., N.W.
Washington, D.C.  20549

Re:      Amarillo Biosciences, Inc. ("Amarillo Biosciences")
         Form 8-K, Filed August   25, 2004
         File No.: 0-20791

Dear Mr. Young:

      The following  are our  responses to your comment  letter dated August 24,
2004.  Our  responses are numbered to  correspond  with the numbered  paragraphs
included in your comment letter.

General

1.    We have provided in writing that Amarillo Biosciences acknowledges that:

            Amarillo Biosciences is responsible for the adequacy and accuracy of
            the disclosure in the filing;

            The staff  comments  or changes to  disclosure  in response to staff
            comments in the filings by the staff do not foreclose the Commission
            from taking any action with respect to the filing; and

            Amarillo  Biosciences  may not assert staff comments as a defense in
            any proceedings  initiated by the Commission or any person under the
            federal securities laws of the United States of America.

            2. We have  revised  the filing to discuss  the former  accountant's
            report for each of the past two years.

            3. We have  revised the filing  address  the two most recent  fiscal
            years and  subsequent  interim  period  through the dismissal of the
            former accountant and have deleted "in connection with the audit"

<PAGE>

            4. We have revised the filing to delete the  reference to the former
            accountant in providing  disclosures  required by Item  304(a)(2) of
            Regulation S-B.

            5. We have  filed  an  updated  letter  from the  former  accountant
            covering the revised disclosures.

                                                     Very truly yours,

                                                     Amarillo Biosciences, Inc.

                                                     Joseph M. Cummins, DVM, PhD
                                                     Chief Executive Officer and
                                                     Chief Financial Officer


</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
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