<PAGE> PAGE 1
000 B000000 05/31/97
000 C000000 0000764859
000 D000000 N
000 E000000 NF
000 F000000 Y
000 G000000 N
000 H000000 N
000 I000000 3.0.a
000 J000000 U
001 A000000 AMERICAN PENSION INVESTORS TRUST
001 B000000 811-4262
001 C000000 8048461361
002 A000000 2303 YORKTOWN AVENUE
002 B000000 LYNCHBURG
002 C000000 VA
002 D010000 24501
003 000000 N
004 000000 N
005 000000 N
006 000000 N
007 A000000 Y
007 B000000 4
007 C010100 1
007 C020100 AMERICAN PENSION INVESTORS TRUST GROWTH FUND
007 C030100 N
007 C010200 2
007 C020200 AMERICAN PENSION INVESTORS TRUST T-1 TREASURY
007 C030200 N
007 C010300 3
007 C020300 AMERICAN PENSION INVESTORS TRUST CAPITAL INCO
007 C030300 N
007 C010400 4
007 C010500 5
007 C010600 6
007 C020600 AMERICAN PENSION INVESTORS TRUST YORKTOWN CLA
007 C030600 N
007 C010700 7
007 C010800 8
007 C010900 9
007 C011000 10
077 A000000 Y
077 B000000 Y
SIGNATURE CHARLES D. FOSTER
TITLE CHIEF FINAN. OFFICER
COOPERS Coopers & Lybrand L.L.P.
& LYBRAND a professional services firm
REPORT OF INDEPENDENT ACCOUNTANTS
To the Board of Trustees of
American Pension Investors Trust:
In planning and performing our audit of the financial statements and
financial highlights of American Pension Investors Trust (comprised of the
Growth Fund, T-1 Treasury Trust, Capital Income Fund, and Yorktown Classic Value
Trust) for the year ended May 31, 1997, we considered its internal control
structure, including procedures for safeguarding securities, in order to
determine our auditing procedures for the purpose of expressing our opinion on
the financial statements and financial highlights and to comply with the
requirements of Form N-SAR, not to provide assurance on the internal control
structure.
The management of American Pension Investors Trust is responsible for
establishing and maintaining an internal control structure. In fulfilling this
responsibility, estimates and judgments by management are required to assess the
expected benefits and related costs of internal control structure policies and
procedures. Two of the objectives of an internal control structure are to
provide management with reasonable, but not absolute, assurance that assets are
safeguarded against loss from unauthorized use or disposition and that
transactions are executed in accordance with management's authorization and
recorded properly to permit preparation of financial statements in conformity
with generally accepted accounting principles.
Because of inherent limitations in any internal control structure, errors
or irregularities may occur and not to be detected. Also, projection of any
evaluation of the structure to future periods is subject to the risk that it may
become inadequate because of changes in conditions or that the effectiveness of
the design and operation may deteriorate.
Our consideration of the internal control structure would not necessarily
disclose all matters in the internal control structure that might be material
weaknesses under standards established by the American Institute of Certified
Public Accountants. A material weakness is a condition in which the design or
operation of the specific internal control structure elements does not reduce to
a relatively low level the risk that errors or irregularities in amounts that
would be material in relation to the financial statements and financial
highlights being audited may occur and not be detected within a timely period by
employees in the normal course of performing their assigned functions. However,
we noted no matters involving the internal control structure, including
procedures for safeguarding securities, that we consider to be material
weaknesses, as defined above, as of May 31, 1997.
This report is intended solely for the information and use of the Board of
Trustees and management of American Pension Investors Trust and the Securities
and Exchange Commission.
COOPERS & LYBRAND L.L.P.
Baltimore, Maryland
June 13, 1997
Coopers & Lybrand L.L.P. is a member of Coopers & Lybrand International, a
limited liability association incorporated in Switzerland.
