February 20, 2020

Robert L. Salomon
Chief Financial Officer
Beazer Homes USA Inc
1000 Abernathy Road, NE
Suite 260
Atlanta, GA 30328

       Re: Beazer Homes USA Inc
           Form 10-K for the year ended September 30, 2019
           Filed November 13, 2019
           File No. 001-12822

Dear Mr. Salomon:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the year ended September 30, 2019

Item 6. Selected Financial Data, page 24

1.    We note your disclosure of a net debt ratio on page 24. Please revise
your disclosure to
      include a reconciliation of net debt to its most comparable GAAP measure
pursuant to
      Item 10(e)(i)(B) of Regulation S-K.
2.    We note that you have added back stock based compensation expense to
arrive at the
      measure of EBITDA presented on page 26. Please tell us why you believe
this
      presentation complies with Question 103.01 of the Non-GAAP C&DIs, or
revise in future
      filings.
Note (2) Basis of Presentation and Summary of Significant Accounting Policies
Accounts Receivable and Allowance, page 51
 Robert L. Salomon
Beazer Homes USA Inc
February 20, 2020
Page 2
3.    We note your disclosure on page 51 that accounts receivable include
escrow deposits to be
      received from title companies associated with closed homes. We also note
your disclosure
      on page 55 that cash from home closings held in escrow for your benefit
are considered
      deposits in-transit and classified as cash. Please clarify for us this
apparent discrepancy
      and revise your disclosure in future filings as appropriate.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Jorge Bonilla at 202-551-3414 or Kristi Marrone at
202-551-3429 if
you have questions.



                                                           Sincerely,
FirstName LastNameRobert L. Salomon
                                                           Division of
Corporation Finance
Comapany NameBeazer Homes USA Inc
                                                           Office of Real
Estate & Construction
February 20, 2020 Page 2
cc:       Keith L. Belknap
FirstName LastName