SEC Comment Letter for CAROLINA INVESTMENT PARTNERS LIMITED PARTNERSHIP (CIK 0000789457) — Jul 14, 2005
CAROLINA INVESTMENT PARTNERS LIMITED PARTNERSHIP (CIK 0000789457)
Date: July 14, 2005 · CIK: 0000789457 · Accession: 0000000000-05-036241
AI Filing Summary & Sentiment
File numbers found in text: 000-15571
Referenced dates: May 13, 2005
Letter
July 14, 2005 VIA U.S. MAIL AND FAX (919) 783-9934 Alton L. Smith, III General Partner and Principal Financial Officer Carolina Investment Partners, Limited Partnership 4000 Blue Ridge Road, Suite 100 Raleigh, North Carolina, 27612
Re: Carolina Investment Partners, Limited Partnership Form 10-K for the year ended December 31, 2004 File No. 000-15571
Dear Mr. Smith:
We have reviewed your response letter dated May 13, 2005 and have the following additional comments.
Where indicated, we think you should revise your document in response to these comments. If you disagree with our comments, we will consider your explanation as to why our comments are not applicable. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Form 10-K for the fiscal year ended December 31, 2004
Statement of Cash Flows, page F-5
1. We have considered your response to our prior comment 1. In your response you indicate that the Company issued checks to limited partners to replace distribution checks that became void based on the age. Explain to us how this is different from a distribution to limited partners. Please tell us your basis in GAAP for reflecting the amount as an operating activity in your Statement of Cash Flows. Additionally, please tell us how the recordation of the distributions not claimed by the limited partners was originally reflected in your Statement of Cash Flows.
Form 10-Q for the quarter ended March 31, 2005
Note B Land Held For Investment and Related Commitments and Transactions, page 6
2. We have considered your response to our prior comment 3. We note that you received a 1.99 acre parcel from the North Carolina Department of Transportation during the first quarter of 2005. Explain to us any relation that this land has to the dedication of 1.6 acres to the Town of Cary noted in our prior comment 3. Also, tell us your basis in GAAP for recording the 1.99 acre parcel as revenue.
3. To the extent that the receipt of the 1.99 acre parcel did not result in cash flows, revise the statement of cash flows as appropriate to exclude the noncash effect of this transaction and report it in accordance with paragraph 32 of SFAS 95.
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response.
If you have any questions, you may contact Robert Telewicz at (202) 551-3438 or me at (202) 551-3414.
Sincerely,
Jorge Bonilla
Senior Staff Accountant
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July 14, 2005
VIA U.S. MAIL AND FAX (919) 783-9934
Alton L. Smith, III
General Partner and Principal Financial Officer
Carolina Investment Partners, Limited Partnership
4000 Blue Ridge Road, Suite 100
Raleigh, North Carolina, 27612
Re: Carolina Investment Partners, Limited Partnership
Form 10-K for the year ended December 31, 2004
File No. 000-15571
Dear Mr. Smith:
We have reviewed your response letter dated May 13, 2005 and
have the following additional comments.
Where indicated, we think you should revise your document in
response to these comments. If you disagree with our comments, we
will consider your explanation as to why our comments are not
applicable. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Form 10-K for the fiscal year ended December 31, 2004
Statement of Cash Flows, page F-5
1. We have considered your response to our prior comment 1. In
your
response you indicate that the Company issued checks to limited
partners to replace distribution checks that became void based on
the
age. Explain to us how this is different from a distribution to
limited partners. Please tell us your basis in GAAP for
reflecting
the amount as an operating activity in your Statement of Cash
Flows.
Additionally, please tell us how the recordation of the
distributions
not claimed by the limited partners was originally reflected in
your
Statement of Cash Flows.
Form 10-Q for the quarter ended March 31, 2005
Note B Land Held For Investment and Related Commitments and
Transactions, page 6
2. We have considered your response to our prior comment 3. We
note
that you received a 1.99 acre parcel from the North Carolina
Department of Transportation during the first quarter of 2005.
Explain to us any relation that this land has to the dedication of
1.6 acres to the Town of Cary noted in our prior comment 3. Also,
tell us your basis in GAAP for recording the 1.99 acre parcel as
revenue.
3. To the extent that the receipt of the 1.99 acre parcel did not
result in cash flows, revise the statement of cash flows as
appropriate to exclude the noncash effect of this transaction and
report it in accordance with paragraph 32 of SFAS 95.
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.
If you have any questions, you may contact Robert Telewicz
at
(202) 551-3438 or me at (202) 551-3414.
Sincerely,
Jorge Bonilla
Senior Staff Accountant
??
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Mr. Smith, III
Carolina Investment Partners, Limited Partnership
July 14, 2005
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