SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                       1999 BROADWAY LIMITED PARTNERSHIP
                                7 Bulfinch Place
                                    Suite 500
                           Boston, Massachusetts 02114

                                   May 5, 2005

VIA EDGAR AND FACSIMILE

Ms. Cicely Luckey
Securities and Exchange Commission
450 Fifth Street
Washington, D.C. 20549

      Re:   1999 Broadway Associates Limited Partnership
            Form 10KSB for the year ended December 31, 2004
            File No. 000-20273

Dear Ms. Luckey:

      We are responding on behalf of 1999 Broadway Associates Limited
Partnership ("1999 Broadway") to your letter of comment, dated April 19, 2005,
with respect to the above-referenced filing by 1999 Broadway with respect to
1999 Broadway's 10-KSB for the year ended December 31, 2004.

      In this regard, this letter will respond to the one comment set forth in
your letter of April 19, 2005.

Comment: As stated on page 21, "Deferred Lease Termination Fee has been deferred
and is being amortized into income for financial statement purposes until such
time as a new tenant occupies the vacated space." Supplementally tell us what
the basis in GAAP was for determining when to recognize the termination fee into
income.

Response: 1999 Broadway Associates Limited Partnership (the "Partnership") is a
publicly held but not traded limited partnership which owns a single office
building with a garage.

      In December 2001, a tenant paid a lease termination fee to the
Partnership. The property mortgage holder maintained control of the cash
proceeds in a reserve account to be used for future tenant improvements. We
believe that the proceeds of the lease termination fee would not immediately
accrue to the benefit of the Partnership; therefore, the Partnership amortized
the fee to income to more closely match the anticipated cash benefits to be
received.

                                                  Sincerely,

                                                  /s/ Thomas C. Staples
                                                  Thomas C. Staples

<PAGE>

                                7 Bulfinch Place
                                    Suite 500
                           Boston, Massachusetts 02114

                                   May 5, 2005

Securities and Exchange Commission
500 North Capital Street
Washington, D.C. 20549

      Re:   1999 Broadway Associates Limited Partnership
            Form 10KSB for the year ended December 31, 2004
            File No. 000-20273

Gentlemen:

Reference is made to the Annual Report on Form 10-KSB for the year ended
December 31, 2004 filed by 1999 Broadway Associates Limited Partnership ("1999
Broadway") with the Securities and Exchange Commission (the "Commission").

1999 Broadway hereby acknowledges that:

1.    1999 Broadway is responsible for the adequacy and accuracy of the
      disclosure made in the material that is filed with the Commission.

2.    Staff comments or changes to disclosure in response to Staff comments do
      not foreclose the Commission from taking any action with respect to the
      filed material; and

3.    1999 Broadway may not assert Staff comments as a defense to any proceeding
      initiated by the Commission or any person under the federal securities
      laws of the United States.

Very truly yours,

1999 BROADWAY ASSOCIATES
 LIMITED PARTNERSHIP

By: Winthrop Financial Associates, A Limited Partnership
    Managing General Partner

    By: /s/ Thomas C. Staples
        -------------------------
        Thomas C. Staples
        Chief Financial Officer
</TEXT>
</DOCUMENT>