TUTOR PERINI CORP — Regulatory Filings 2021

May 4, 2021

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Tutor Perini Corporation

15901 Olden Street

Sylmar, CA 91342

Tel: 818/362-8391 Fax: 818/367-5379

May 4, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F St. NE

Washington, DC 20549

Attn: Ameen Hamady and Kristi Marrone

Re:
Form 10-K for the year ended December 31, 2020
Response dated April 20, 2021
File No. 001-06314

Ladies and Gentlemen:

Set forth below is the response of Tutor Perini Corporation (the “Company”) to the letter dated May 4, 2021 containing further comment of the staff (the “Staff”) of the Securities and Exchange Commission on the Company’s Annual Report on Form 10-K for the year ended December 31, 2020.

For ease of reference, the Staff’s comment is reproduced below in bold.

Form 10-K for the year ended December 31, 2020

Note 7. Financial Commitments, page F-27

1. We note your response to comment 1. In future filings, please ensure your disclosures clearly disclose any gains or losses that may have resulted from the extinguishment, including where the gains or losses are presented in your financial statements.

Response:

In future filings, the Company will ensure that our disclosures clearly disclose any gains or losses that may have resulted from the extinguishment of debt, including where the gains or losses are presented in our financial statements.

Please feel free to contact me at 818/362-8391 if you have any questions.

Sincerely,

/s/ Gary G. Smalley

Gary G. Smalley

Executive Vice President and Chief Financial Officer