Mail Stop 4561
	 								May 26, 2006

VIA U.S. MAIL AND FAX (248) 208-2640

Mr. Gary A. Shiffman
Chief Executive Officer
Sun Communities, Inc.
27777 Franklin Road, Suite 200
Southfield, MI 48034

      Re:	Sun Communities, Inc
      	Form 10-K for the year ended December 31, 2005
      	Filed March 16, 2006
      File No. 333-72461

Dear Mr. Shiffman:

      We have reviewed your filing and have the following comment.
We have limited our review of your filing to those issues we have
addressed in our comment.  Please be as detailed as necessary in
your
explanations.  In our comment, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the year ended December 31, 2005

2. Rental Property, page F-17

1. Please tell us and in future filings disclose your policies for
allocating purchase price to acquired assets and liabilities.
Refer
to paragraphs 35 - 39 of SFAS 141.  Specifically, address in your
disclosure acquired intangible assets, such as in-place leases,
and
explain to us why it appears you have not identified any in-place
leases as acquired intangible assets in accordance with paragraph
39
of SFAS 141.

*    *    *    *

      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comment and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
response to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;


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

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      If you have any questions, you may contact Eric McPhee at
(202)
551-3693 or me at (202) 551-3486.

Sincerely,



Daniel L. Gordon
Branch Chief


Mr. Gary A. Shiffman
Sun Communities, Inc.
May 26, 2006
Page 1