November 8, 2006

Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

         Re:      American Racing Capital, Inc.
                  Registration Statement on Form SB-2
                  Filed with the Securities and Exchange Commission on
                  September 11, 2006
                  (Registration No. 333-137231)
                  Request for Withdrawal

Ladies and Gentlemen:

Pursuant to Rule 477  promulgated  under the  Securities  Act of 1933,  American
Racing Capital,  Inc. (the  "Company")  hereby applies for the withdrawal of its
registration  statement on Form SB-2,  File No.  333-137231,  which was filed on
September 11, 2006 (the "Registration Statement").

Such  withdrawal  is  requested,  as the Company is  uncertain  of the basis for
determining that the transaction is  appropriately  characterized as an offering
to be made by or on behalf of persons other than the registrant, consistent with
Rule  415(a)(1)(i).  As a result, the Company determined that it should withdraw
the SB-2.

No  sales  of any of the  Company's  securities  have  been  completed  and  the
Registration  Statement  has not  been  declared  effective  by the  Commission.
However,  the Company may undertake a private offering in the future in reliance
on Securities Act Rule 155(c).

Should you have any comments please contact the Company's legal counsel, Richard
I. Anslow at (732) 409-1212.

Very truly yours,

AMERICAN RACING CAPITAL, INC.


By:  /s/ A. Robert Koveleski
     ----------------------------------------------
     A. Robert Koveleski
     Chief Executive Officer