July 11, 2024

Faith Zaslavsky
Chief Executive Officer
IMAC Holdings, Inc.
3401 Mallory Lane, Suite 100
Franklin, TN 37067

       Re: IMAC Holdings, Inc.
           Preliminary Proxy Statement on Schedule 14A
           Response dated June 25, 2024
           File No. 001-38797
Dear Faith Zaslavsky:

       We have reviewed your June 25, 2024 response to our comment letter and
have the
following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to this letter, we may have additional
comments. Unless we
note otherwise, any references to prior comments are to comments in our June
14, 2024 letter.

Preliminary Proxy Statement on Schedule 14A filed June 6, 2024
General

1.     We note your response to prior comment 1. While we do not have any
further comments
       at this time regarding your response, please confirm your understanding
that our decision
       not to issue additional comments should not be interpreted to mean that
we either agree or
       disagree with your analysis or response with respect to this matter.
 July 11, 2024
Page 2

       Please contact Juan Grana at 202-551-6034 or Jane Park at 202-551-7439
with any other
questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Industrial
Applications and
                                                         Services
cc:   Carol W. Sherman, Esq.