CERTIFICATIONS

I, Lacy B. Herrmann, certify that:

1. I have reviewed this report on Form N-Q of Churchill Tax-Free Trust;

2. Based on my knowledge, this report does not contain any untrue statement
   of a material fact or omit to state a material fact necessary to make the
   statements made, in light of the circumstances under which such statements
   were made, not misleading with respect to the period covered by this
   report;

3. Based on my knowledge, the schedules of investments included in this
   report fairly present in all material respects the investments of the
   registrant as of the end of the fiscal quarter for which the report is
   filed;

4. The registrant's other certifying officer(s) and I are responsible for
   establishing and maintaining disclosure controls and procedures (as
   defined in Rule 30a-3(c) under the Investment Company Act of 1940) and
   internal control over financial reporting (as defined in Rule 30a-3(d)
   under the Investment Company Act of 1940) for the registrant and have:

   (a) Designed such disclosure controls and procedures, or caused such
   disclosure controls and procedures to be designed under our supervision,
   to ensure that material information relating to the registrant, including
   its consolidated subsidiaries, is made known to us by others within those
   entities, particularly during the period in which this report is being
   prepared;

   (b) Designed such internal control over financial reporting, or caused
   such internal control over financial reporting to be designed under our
   supervision, to provide reasonable assurance regarding the reliability of
   financial reporting and the preparation of financial statements for
   external purposes in accordance with generally accepted accounting
   principles;

   (c) Evaluated the effectiveness of the registrant's disclosure controls
   and procedures and presented in this report our conclusions about the
   effectiveness of the disclosure controls and procedures, as of a date
   within 90 days prior to the filing date of this report, based on such
   evaluation; and

   (d) Disclosed in this report any change in the registrant's internal
   control over financial reporting that occurred during the registrant's
   most recent fiscal quarter that has materially affected, or is
   reasonably likely to materially affect, the registrant's internal
   control over financial reporting; and

5. The registrant's other certifying officer(s) and I have disclosed to the
   registrant's auditors and the audit committee of the registrant's board of
   directors (or persons performing the equivalent functions):

   (a) All significant deficiencies and material weaknesses in the design or
   operation of internal control over financial reporting which are reasonably
   likely to adversely affect the registrant's ability to record, process,
   summarize, and report financial information; and

   (b) Any fraud, whether or not material, that involves management or other
   employees who have a significant role in the registrant's internal control
   over financial reporting.

Date: November 29, 2004

/s/ Lacy B. Herrmann
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Lacy B. Herrmann
Chairman of the Board




I, Diana P. Herrmann, certify that:

1.  I have reviewed this report on Form N-Q of Churchill Tax-Free Trust;

2. Based on my knowledge, this report does not contain any untrue statement
   of a material fact or omit to state a material fact necessary to make the
   statements made, in light of the circumstances under which such statements
   were made, not misleading with respect to the period covered by this
   report;

3. Based on my knowledge, the schedules of investments included in this
   report fairly present in all material respects the investments of the
   registrant as of the end of the fiscal quarter for which the report is
   filed;

4. The registrant's other certifying officer(s) and I are responsible for
   establishing and maintaining disclosure controls and procedures (as
   defined in Rule 30a-3(c) under the Investment Company Act of 1940) and
   internal control over financial reporting (as defined in Rule 30a-3(d)
   under the Investment Company Act of 1940) for the registrant and have:

   (a) Designed such disclosure controls and procedures, or caused such
   disclosure controls and procedures to be designed under our supervision,
   to ensure that material information relating to the registrant, including
   its consolidated subsidiaries, is made known to us by others within those
   entities, particularly during the period in which this report is being
   prepared;

   (b) Designed such internal control over financial reporting, or caused
   such internal control over financial reporting to be designed under our
   supervision, to provide reasonable assurance regarding the reliability of
   financial reporting and the preparation of financial statements for
   external purposes in accordance with generally accepted accounting
   principles;

   (c) Evaluated the effectiveness of the registrant's disclosure controls
   and procedures and presented in this report our conclusions about the
   effectiveness of the disclosure controls and procedures, as of a date
   within 90 days prior to the filing date of this report, based on such
   evaluation; and

   (d) Disclosed in this report any change in the registrant's internal
   control over financial reporting that occurred during the registrant's
   most recent fiscal quarter that has materially affected, or is
   reasonably likely to materially affect, the registrant's internal
   control over financial reporting; and

5. The registrant's other certifying officer(s) and I have disclosed to the
   registrant's auditors and the audit committee of the registrant's board of
   directors (or persons performing the equivalent functions):

   (a) All significant deficiencies and material weaknesses in the design or
   operation of internal control over financial reporting which are reasonably
   likely to adversely affect the registrant's ability to record, process,
   summarize, and report financial information; and

   (b) Any fraud, whether or not material, that involves management or other
   employees who have a significant role in the registrant's internal control
   over financial reporting.

Date: November 29, 2004

/s/ Diana P. Herrmann
- -----------------------------
Diana P. Herrmann
Vice Chair, Trustee and President




I, Joseph P. DiMaggio, certify that:

1.  I have reviewed this report on Form N-Q of Churchill Tax-Free Trust;

2. Based on my knowledge, this report does not contain any untrue statement
   of a material fact or omit to state a material fact necessary to make the
   statements made, in light of the circumstances under which such statements
   were made, not misleading with respect to the period covered by this
   report;

3. Based on my knowledge, the schedules of investments included in this
   report fairly present in all material respects the investments of the
   registrant as of the end of the fiscal quarter for which the report is
   filed;

4. The registrant's other certifying officer(s) and I are responsible for
   establishing and maintaining disclosure controls and procedures (as
   defined in Rule 30a-3(c) under the Investment Company Act of 1940) and
   internal control over financial reporting (as defined in Rule 30a-3(d)
   under the Investment Company Act of 1940) for the registrant and have:

   (a) Designed such disclosure controls and procedures, or caused such
   disclosure controls and procedures to be designed under our supervision,
   to ensure that material information relating to the registrant, including
   its consolidated subsidiaries, is made known to us by others within those
   entities, particularly during the period in which this report is being
   prepared;

   (b) Designed such internal control over financial reporting, or caused
   such internal control over financial reporting to be designed under our
   supervision, to provide reasonable assurance regarding the reliability of
   financial reporting and the preparation of financial statements for
   external purposes in accordance with generally accepted accounting
   principles;

   (c) Evaluated the effectiveness of the registrant's disclosure controls
   and procedures and presented in this report our conclusions about the
   effectiveness of the disclosure controls and procedures, as of a date
   within 90 days prior to the filing date of this report, based on such
   evaluation; and

   (d) Disclosed in this report any change in the registrant's internal
   control over financial reporting that occurred during the registrant's
   most recent fiscal quarter that has materially affected, or is
   reasonably likely to materially affect, the registrant's internal
   control over financial reporting; and

5. The registrant's other certifying officer(s) and I have disclosed to the
   registrant's auditors and the audit committee of the registrant's board of
   directors (or persons performing the equivalent functions):

   (a) All significant deficiencies and material weaknesses in the design or
   operation of internal control over financial reporting which are reasonably
   likely to adversely affect the registrant's ability to record, process,
   summarize, and report financial information; and

   (b) Any fraud, whether or not material, that involves management or other
   employees who have a significant role in the registrant's internal control
   over financial reporting.

Date: November 29, 2004

/s/ Joseph P. DiMaggio
- -----------------------------
Joseph P. DiMaggio
Chief Financial Officer and Treasurer