UPLOAD: SEC-generated letter

Room 4561
June 21, 2006

Stephen M. Bennett
President and Chief Executive Officer
Intuit Inc.
2700 Coast Avenue
Mountain View, CA 94043

Re: Intuit Inc.
Form 10-K for the Fiscal Year Ended July 31, 2005
Filed September 26, 2005
Form 10-Q for the Quarterly Period Ended April 30, 2006
Filed June 9, 2006
Form 8-K Filed May 17, 2006
File no. 0-21180

Dear Mr. Bennett:

We have reviewed your response letter dated May 24, 2006 and
have the following comments. Where indicated, we think you should
revise your document in response to these comments. If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation. In our comment, we 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 comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 8-K Filed May 17, 2006
1. We note your response to our previous comments no. 1 and 2.
Throughout your revised Form 8-K disclosures, the Company makes
the
statement "We believe that these non-GAAP financial measures
provide
meaningful supplemental information regarding Intuit`s operating
results primarily because they exclude amounts that we do not
consider part of ongoing operating results when assessing the
performance of the organization, our operating segments or our
senior
management." This statement appears overly broad and yet in your
discussion of the specific items excluded from your non-GAAP
financial measures, the Company continually refers back to this
statement as the reason for excluding such amounts. We note no
substantive disclosure that addresses the disclosure requirements
in
Question 8 of the Frequently Asked Questions Regarding the Use of
Non-GAAP Financial Measures (FAQ). For example, your response to
comment no. 1 indicates that "segment managers are not held
accountable for share-based compensation charges impacting their
business unit`s operating income (loss) and accordingly, share-
based
compensation charges are excluded from our measures of segment
performance. While share-based compensation is a significant
expense
affecting the company`s results of operations, management excludes
share-based compensation from the budget and planning process for
our
business units." The Company included similar discussions in your
response with regards to the exclusion of acquisition costs and
yet
you did not include this information in your Form 8-K. We
continue
to believe that your discussion of non-GAAP performance measures
does
not adequately explain (a) the economic substance behind
management`s
decision to use such a measure; (b) the material limitations
associated with use of the non-GAAP financial measure as compared
to
the use of the most directly comparable GAAP financial measure;
(c)
the manner in which management compensates for these limitations
when
using the non-GAAP financial measure; and (d) the substantive
reasons
why management believes the non-GAAP financial measure provides
useful information. Please provide the revised disclosures that
that
the Company intends to include in their next Form 8-K to
sufficiently
meet the requirements of FAQ 8.

Form 10-Q for the Quarterly Period Ended April 30, 2006

Condensed Consolidated Statements of Operations, page 3
2. We note your disclosures on the face of the Consolidated
Statements of Operations regarding a discussion pro-forma stock
based
compensation pursuant to SFAS 123. Please explain how the Company
determined that such disclosure, which is normally included in the
footnotes to the financial statements, is appropriate on the face
of
the financial statements.

As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T. You
may wish to provide us with marked copies of any amendment to
expedite our review. Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information. Detailed cover letters greatly facilitate
our
review. Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

You may contact Kari Jin, Staff Accountant, at (202) 551-
3481
or me at (202) 551-3730 if you have questions regarding these
comments.


Sincerely,


Kathleen Collins
Accounting Branch Chief
Mr. Stephen M. Bennett
Intuit Inc.
June 21, 2006
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