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SEC Comment Letter for CHRISKEN PARTNERS CASH INCOME FUND L P (CIK 0000815278) — Apr 26, 2005

CHRISKEN PARTNERS CASH INCOME FUND L P (CIK 0000815278)
Date: April 26, 2005 · CIK: 0000815278 · Accession: 0000000000-05-020258

AI Filing Summary & Sentiment

File numbers found in text: 000-17602

Date
December 31, 2004
Author
Cicely Luckey
Form
UPLOAD
Company
CHRISKEN PARTNERS CASH INCOME FUND L P (CIK 0000815278)

Letter

Mail Stop 0409 VIA U.S. MAIL AND FAX (312)454-1627 John F. Kennedy 345 North Canal Street Suite 201C Chicago, Illinois 60606

Re: Chrisken Partners Cash Income Fund L.P. Form 10-K for the year ended December 31, 2004 File no. 000-17602

Dear Mr. Kennedy:

We have reviewed your filing 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.

Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental 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 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.

Financial statements

General 1. Considering the sale of your remaining property in January 2005, and your adopted plan of liquidation, please explain why you have not applied the liquidation basis of accounting as of December 31, 2004.

Report of Independent Registered Public Accounting Firm, page 15 2. We note that your independent accountant`s audit report is not signed. Amend your form 10-K to include a signed audit report.

* * * *

As appropriate, please amend your Form 10-K and respond to these comments within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your response 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 Robert Telewicz, Staff Accountant, at (202) 824-5356 or the undersigned at (202) 942-1964 if you have questions.

Sincerely,
Cicely Luckey
Accounting Branch Chief

Show Raw Text
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<TEXT>

Mail Stop 0409

VIA U.S. MAIL AND FAX (312)454-1627

John F. Kennedy
345 North Canal Street
Suite 201C
Chicago, Illinois 60606

Re: Chrisken Partners Cash Income Fund L.P.
	Form 10-K for the year ended December 31, 2004
	File no. 000-17602

Dear Mr. Kennedy:

      We have reviewed your filing 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.

      Where indicated, we think you should revise your document in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comments are inapplicable or a revision
is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental 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 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.

Financial statements

General
1. Considering the sale of your remaining property in January
2005,
and your adopted plan of liquidation, please explain why you have
not
applied the liquidation basis of accounting as of December 31,
2004.

Report of Independent Registered Public Accounting Firm, page 15
2. We note that your independent accountant`s audit report is not
signed.  Amend your form 10-K to include a signed audit report.

*    *    *    *

      As appropriate, please amend your Form 10-K and respond to
these comments within 10 business days or tell us when you will
provide us with a response.  Please file your response letter on
EDGAR.  Please understand that we may have additional comments
after
reviewing your response 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 Robert Telewicz, Staff Accountant, at (202)
824-5356 or the undersigned at (202) 942-1964 if you have
questions.

						Sincerely,

Cicely Luckey
Accounting Branch Chief

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Chrisken Partners Cash Income Fund L.P.
April 26, 2005

</TEXT>
</DOCUMENT>