October 22, 2018 Mark E. Patten Chief Financial Officer Consolidated-Tomoka Land Co. 1140 N. Williamson Blvd. Suite 140 Daytona Beach, FL 32114 Re: Consolidated-Tomoka Land Co. Form 10-K for the Fiscal Year Ended December 31, 2017 Filed February 28, 2018 File No. 001-11350 Dear Mr. Patten: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2017 Schedule III Real Estate and Accumulated Depreciation, page F-55 1. In future periodic filings, please disclose the total aggregate cost of the properties for Federal income tax purposes in accordance with Rule 12-28 of Regulation S-X. Provide similar disclosure for the aggregate carrying amount of mortgages in Schedule IV in accordance with Rule 12-29 of Regulation S-X. In closing, 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. Mark E. Patten Consolidated-Tomoka Land Co. October 22, 2018 Page 2 You may contact Isaac Esquivel, Staff Accountant, at (202) 551-3395 or Kristi Marrone, Staff Accountant, at (202) 551-3429 with any questions. Sincerely, FirstName LastNameMark E. Patten Division of Corporation Finance Comapany NameConsolidated-Tomoka Land Co. Office of Real Estate and October 22, 2018 Page 2 Commodities FirstName LastName