SecProbe.io

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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>upload.txt
<DESCRIPTION>ITEM 4.01 8-K LETTER 11/18/04 - TANGEN
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Mail Stop 04-06

November 18, 2004

Via U.S. Mail

Clifford Rhee
President
Thomas Equipment, Inc.
f/k/a Maxim Mortgage Corp.
1818 North Farwell Avenue
Milwaukee, WI  53202

Re:   	Thomas Equipment, Inc.
Form 8-K, Item 4.01, filed November 15, 2004
File No. 333-44586

Dear Mr. Rhee:

We have reviewed your filing and have the following comments.  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.  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.

Form 8-K filed on November 15, 2004

Item 4.01 Changes in Registrant`s Certifying Accountant
1. Item 304(a)(1)(ii) of Regulation S-B requires a statement whether
the accountant`s report on the financial statements for either of the
past two years contained an adverse opinion or a disclaimer of opinion
or was qualified or modified as to uncertainty, audit scope or
accounting principles; and a description of the nature of each such
adverse opinion, disclaimer of opinion, modification or qualification.
Amend accordingly.
2.
Item 304(a)(1)(iii) of Regulation S-B requires a statement whether the
decision to change accountants was recommended or approved by the
board of directors or an audit or similar committee of the board of
directors.  Amend accordingly.
3. When you engage a new accountant, please report the engagement in a
new Form 8-K and comply with the requirements of Regulation S-B Item
304 (a)(2).  In making any disclosures about consultations with your
new accountants, please ensure you disclose any consultations up
through the date of engagement.
4. We note that your name has changed to Thomas Equipment, Inc.
Within the EDGAR system, however, you continue to be identified as
Maxim Mortgage Corporation.  Your company information should be
updated through the EDGAR website as soon as possible. For assistance
in updating company information you may contact Filer Support at (202)
942-8900.

General

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.  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 in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; 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 filing or in response to our
comment on your filing.

********

Please provide the supplemental information requested above within 10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The amendment
requested should be filed as promptly as possible.  Please note that
if you require longer than 10 business days to respond, you should
contact the staff immediately to request additional time.  Any
questions regarding the above should be directed to me at (202) 942-
1987, or in my absence, to Robert Benton at (202) 942-1811.

Sincerely,

Tamara Tangen
Staff Accountant

Thomas Equipment, Inc.
November 18, 2004
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