Two examples were built, with the Japanese Military's control of resources preventing any further production.
In 1938, the Tachikawa Aircraft Company, which was building large numbers of its Ki-9 and Ki-17 basic and primary trainers for the Imperial Japanese Army, began work on a new training aircraft for use by civilian training schools.
It had a fabric-covered welded steel tube fuselage and a wood and metal wing.
[2] The first prototype was powered by a 150 horsepower (110 kW) Gasuden Jimpu seven-cylinder radial engine driving a two-bladed propeller and made its first flight on 22 February 1939.
A second prototype, the R-38-Kai was built powered by an experimental 120 horsepower (89 kW) Kosoku KO-4 four-cylinder air-cooled inline engine, produced by a subsidiary of Tachikawa.