SEC Company Response from THACKERAY CORP (CIK 0000354639) — Apr 18, 2005
THACKERAY CORP (CIK 0000354639)
Date: April 18, 2005 · CIK: 0000354639 · Accession: 0000909518-05-000249
AI Filing Summary & Sentiment
Letter
April 18, 2005 Mr. Daniel Gordon Branch Chief US Securities and Exchange Commission 450 Fifth Street NW Washington, DC 20549
Re: Thackeray Corporation Form 10-K for the fiscal year ended December 31, 2004 Filed March 24, 2005 Form 8-K filed March 28, 2005 File No. 1-08254
Dear Mr. Gordon:
Reference is made to your letter to Thackeray Corporation dated April 11, 2005, and to comment 1 of such letter. Thackeray employed the equity method of reporting its investment in BT Orlando Limited Partnership until 2002 when the cumulative absorption of partnership losses reduced Thackeray's investment in BT Orlando to zero, at which time Thackeray ceased absorbing any Partnership losses.
The above process is in accordance with SOP-78-9 Paragraph 15(a) since neither Thackeray nor any of its subsidiaries had a legal obligation as a guarantor or as a general partner of BT Orlando to provide additional financing to the partnership. Thackeray never indicated in any form or manner a commitment to provide additional financing to support the partnership.
Please be advised that Thackeray acknowledges that:
o The company is responsible for the adequacy and accuracy of the disclosure in the filings;
o 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
<PAGE> Mr. Daniel Gordon US Securities and Exchange Commission April 18, 2005 Page 2
o 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.
Sincerely yours,
/s/ Jules Ross
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<TEXT>
April 18, 2005
Mr. Daniel Gordon
Branch Chief
US Securities and Exchange Commission
450 Fifth Street NW
Washington, DC 20549
Re: Thackeray Corporation
Form 10-K for the fiscal year ended December 31, 2004 Filed
March 24, 2005
Form 8-K filed March 28, 2005 File No. 1-08254
Dear Mr. Gordon:
Reference is made to your letter to Thackeray Corporation dated April 11, 2005,
and to comment 1 of such letter. Thackeray employed the equity method of
reporting its investment in BT Orlando Limited Partnership until 2002 when the
cumulative absorption of partnership losses reduced Thackeray's investment in BT
Orlando to zero, at which time Thackeray ceased absorbing any Partnership
losses.
The above process is in accordance with SOP-78-9 Paragraph 15(a) since neither
Thackeray nor any of its subsidiaries had a legal obligation as a guarantor or
as a general partner of BT Orlando to provide additional financing to the
partnership. Thackeray never indicated in any form or manner a commitment to
provide additional financing to support the partnership.
Please be advised that Thackeray acknowledges that:
o The company is responsible for the adequacy and accuracy of the
disclosure in the filings;
o 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
<PAGE>
Mr. Daniel Gordon
US Securities and Exchange Commission
April 18, 2005
Page 2
o 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.
Sincerely yours,
/s/ Jules Ross
Jules Ross
Vice President, Finance
</TEXT>
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