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                             September 29, 2022

       Joseph C. Visconti
       Chief Executive Officer
       Twin Vee PowerCats Co.
       3101 S. U.S. Highway 1
       Fort Pierce, FL 34982

                                                        Re: Twin Vee PowerCats
Co.
                                                            Registration
Statement on Form S-4
                                                            Filed September 9,
2022
                                                            File No. 333-267372

       Dear Mr. Visconti:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-4 filed September 9, 2022

       The Merger Transaction
       Certain U.S. Federal Income Tax Consequences of the Merger, page 96

   1.                                                   Please provide a tax
opinion covering the material federal tax consequences of the
                                                        transaction to
investors and revise your disclosure accordingly. Please refer to Item
                                                        601(b)(8) of Regulation
S-K and Items 4(a)(6) and 21(a) of Form S-4. For guidance in
                                                        preparing the opinion
and related disclosure, please refer to Section III of Staff Legal
                                                        Bulletin No. 19.
 Joseph C. Visconti
FirstName LastNameJoseph
Twin Vee PowerCats   Co. C. Visconti
Comapany 29,
September  NameTwin
               2022 Vee PowerCats Co.
September
Page 2     29, 2022 Page 2
FirstName LastName
Security Ownership of Certain Beneficial Owners and Management...
Ownership of Twin Vee Co. Common Stock Following the Merger, page 151

2.       We note your disclosure on page 32 that following the merger Joseph
Visconti will own
         33.9% of the combined company. Please reconcile this with your
disclosure on page 151.
         If true, please revise to prominently disclose that the combined
company will be a
         controlled company, identify the controlling shareholders and the
shareholders    total
         voting power, and include appropriate risk factor disclosure.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Patrick Fullem at (202) 551-8337 or Erin Purnell at (202)
551-3454 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing
cc:      Leslie Marlow