Mail Stop 7010

March 14, 2006

Via U.S. mail and facsimile

Ian J. McCarthy
President and Chief Executive Officer
Beazer Homes USA, Inc.
1000 Abernathy Road, Suite 1200
Atlanta, GA  30328

	RE:	Beazer Homes USA, Inc.
Form 10-K for the Fiscal Year Ended September 30, 2005
Forms 10-Q for the Fiscal Quarter Ended December 31, 2005
		File No. 1-12822


Dear Mr. McCarthy:

      We have reviewed your response letter dated March 13, 2006
and
have the following additional comment.  If you disagree, we will
consider your explanation as to why our comment is inapplicable.
In
of our comment, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

Form 10-K for the Fiscal Year Ended September 30, 2005

Notes to Financial Statements

(1) Summary of Significant Accounting Policies Presentation, page
39

		We read your response to our comment 4 from our letter
dated March 1, 2006.  Your response does not currently support
your
conclusion that your operating segments have similar
characteristics
and thus can be aggregated, for you have not demonstrated this to
us
and have not addressed the apparent differences in their economic
characteristics and trends.

		Your response states "the economic characteristics which
drive the sale of [your] homebuilding products, and the
homebuilding
industry in general, are the same within each of [your] geographic
locations.  These characteristics include employment growth and
levels of unemployment, the general health of the local
economy..."
Please tell us what consideration you gave to the following:
* Your disclosure on page 22 of your Form 10-K for the fiscal year
ended September 30, 2005 states that the factors which contributed
to
the $130.2 million goodwill impairment charge were certain
underperforming markets in Indiana, Ohio, Kentucky and Charlotte,
North Carolina. The forecasts and valuations of the respective
divisions, along with weaker than anticipated local economies,
particularly in the Midwest markets, and severe price competition,
particularly at entry level price points;
* The differences in the economies driving certain of your
markets,
which have affected your orders and revenues, some of which you
have
described in paragraphs six and seven of your response; and
* The availability of land and your ability to purchase land in
certain regions of the country, which will impact your future
economic performance in these regions.
Please tell us how you determined the above were similar economic
characteristics, which result in similar long-term financial
performance and trends.

		Please provide us with your key metrics used in your
quantitative analysis for each of the last five fiscal years, the
most recent interim periods, and each subsequent year and interim
period for which you have budgeting information for.  Please
include
in your analysis explanations for any apparent differences in
economic characteristics for a given operating segment when
compared
to another operating segment for a period and why these
differences
would not be considered an indication of differences in economic
characteristics.  Please ensure you also include explanations for
any
difference in trends, including your basis for concluding that any
trend was temporary.  Refer to paragraphs 17-18 and 73-74 of SFAS
131; Question 8 of the FASB Staff Implementation Guide for SFAS
131;
and Topic 5 from the minutes of the November 10, 1998 meeting
between
the Professional Standards Group and the SEC staff.










*    *    *    *


      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 letter that keys your responses to our comment
and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
letter on EDGAR.  Please understand that we may have additional
comments after reviewing your response to our comment.

      If you have any questions regarding this comment, please
direct
them to Meagan Caldwell, Staff Accountant, at (202) 551-3754 or,
in
her absence, to the undersigned at (202) 551-3769.


							Sincerely,


							Rufus Decker
							Accounting Branch Chief

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Ian J. McCarthy
Beazer Homes USA, Inc.
March 14, 2006
Page 1 of 3




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE