SEC Comment Letter for FIRST WILKOW VENTURE (CIK 0000037070) — Nov 18, 2005
FIRST WILKOW VENTURE (CIK 0000037070)
Date: Nov. 18, 2005 · CIK: 0000037070 · Accession: 0000000000-05-058594
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 4561
November 10, 2005
VIA U.S. MAIL AND FAX 1-312-726-0468
Mr. Marc R. Wilkow, General Partner and President
First Wilkow Venture
180 North Michigan Avenue
Chicago, Illinois 60601
RE: First Wilkow Venture
Form 10-K for the year ended December 31, 2004
Form 10-Q for the year ended March 31, 2004
File no. 0-7798
Dear Mr.Wilkow:
We have reviewed your letter filed on August 10, 2005 and
have
the following comments. In our comments, we ask you to provide us
with information so we may better understand your disclosure.
After
reviewing this information, we may or may not raise additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.
We welcome any questions you may have about our comments or on any
other aspect of our review. Feel free to call us at the telephone
numbers listed at the end of this letter.
Form 10-K
Note (2) Investments in Real Estate Partnerships and Cotenancies,
page 28
1. We have read and considered your response to our prior comment
one
relating to your investment in limited partnerships. We remain of
the
view that you should account for these investments under the
equity
method in accordance with EITF Topic D-46. Please explain to us
and
quantify the effect that would result from using the equity method
instead of the cost method for the referenced investments.
2. With respect to your investments in limited liability companies
("LLCs"), please explain to us how you considered the provisions
of
EITF 3-16. Please explain to us and quantify the effect that
would
result from using the equity method in accordance with EITF 3-16
instead of the cost method for the referenced investments.
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please file
your
response on EDGAR. If you have any questions, you may contact
Kelly
McCusker at (202) 551-3433 or me at (202) 551-3414.
Sincerely,
Jorge L. Bonilla
Senior Staff Accountant
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First Wilkow Venture
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