SEC Comment Letter for PRESIDENTIAL ASSOCIATES I LTD PARTNERSHIP (CIK 0000726666) — Dec 28, 2005
PRESIDENTIAL ASSOCIATES I LTD PARTNERSHIP (CIK 0000726666)
Date: Dec. 28, 2005 · CIK: 0000726666 · Accession: 0000000000-05-064246
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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December 28, 2005
Mr. Thomas Staples
Chief Financial Officer
Presidential Associates I L.P.
7 Bulfinch Place, Suite 500
P.O. Box 9507
Boston, MA 02114
Re: Presidential Associates I L.P. (Presidential)
Form 10-KSB for the year ended December 31, 2004, as
amended
File No.: 0-12210
Dear Mr. Staples:
We note that the report of Reznick Group, P.C. (principal
auditor) on the financial statements of Presidential (issuer) for
the
two years ended December 31, 2004 refers to the report of another
auditor for the audit of Presidential Towers, an entity in which
Presidential owns a limited partnership interest. The report of
this
other auditor on the financial statements of Presidential Towers
states that the audit was conducted in accordance with auditing
standards generally accepted in the United States of America.
When part of an issuer`s audit is performed by another
auditor,
the principal auditor may divide responsibility with the other
auditor by making reference to the other auditor in his or her
report, or the principal auditor may take responsibility for the
work
of the other auditor by not making reference to the other auditor.
In either case, Regulation S-X requires that all parts of the
audit
be performed in accordance with GAAS, regardless of who performs
the
work. Note that the SEC has stated in Release No. 34-49708
Commission Guidance Regarding the Public Company Accounting
Oversight
Board`s Auditing and Related Professional Practice Standard No. 1
that "references in Commission rules....to GAAS or to specific
standards under GAAS, as they relate to issuers, should be
understood
to mean the standards of the PCAOB plus any applicable rules of
the
Commission."
Therefore, when the principal auditor of an issuer chooses to
make reference to the report of another auditor, the other
auditor`s
report must state that the audit was conducted in accordance with
the
standards of the PCAOB (see the PCAOB`s Auditing Standard No. 1
for
this requirement). It is not appropriate for the report of the
other
auditor to only refer to auditing standards generally accepted in
the
United States of America. Also, please note that the other auditor
is
also expected to comply with the SEC`s auditor independence
requirements outlined in Rule 2-01 of Regulation S-X.
Please advise us of your plans to correct this deficiency in
Presidential`s Form 10-KSB. Please respond within five business
days
of receipt of this letter. You may advise the staff if additional
time is needed to reply. If you have any questions, please call
me
or Louise Dorsey at (202) 551-3400.
Sincerely,
Stephanie L. Hunsaker
Associate Chief Accountant
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Presidential Associates I L.P.
December 28, 2005
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