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