SEC Comment Letter for REEVES TELECOM LTD PARTNERSHIP (CIK 0000314741) — Aug 29, 2005
REEVES TELECOM LTD PARTNERSHIP (CIK 0000314741)
Date: Aug. 29, 2005 · CIK: 0000314741 · Accession: 0000000000-05-044776
AI Filing Summary & Sentiment
File numbers found in text: 000-09305
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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August 29,
2005
Mail Stop 4561
David Stowell
55 Brookville Road
Glen Head
New York, NY 11545
Re: Reeves Telecom Limited Partnership
Form 10-K for the year ended December 31, 2004
Forms 10-Q for the quarters ended March 31, 2005 and
June
30, 2005
File No. 000-09305
Dear Mr. Stowell:
We have reviewed your above referenced filings and have the
following comments. We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents. As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.
In our comments, we ask you to provide us information so we
may
better understand your disclosure. Please be as detailed as
necessary in your explanation. 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 filing.
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 3 - Properties Held For Sale and Property and Equipment, page
F-
9
1. In classifying property as held for sale, please explain to us
on
how you meet criterion 30(d) of SFAS 144 as it relates to that the
transfer of the asset is expected to qualify for recognition as a
completed sale within one year.
2. We note your disclosure that "...the properties held for sale
are
not reported in excess of their fair values." Please tell us how
you
considered paragraph 34 of SFAS 144 that requires that properties
held for sale to be measured at the lower of its carrying amount
or
fair value "less costs to sell."
* * * *
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please file your letter on EDGAR. Please understand that we may
have
additional comments after reviewing your responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.
You may contact Yolanda Crittendon, Staff Accountant, at
(202)
551-3472 or the undersigned at (202) 551-3414 if you have
questions.
Sincerely,
Jorge Bonilla
Senior Staff Accountant
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David Stowell
Reeves Telecom Limited Partnership
August 26, 2005
Page 2
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