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SEC Company Response from ATLAS AMERICA SERIES 25-2004 A L P (CIK 0001283810) — Jul 13, 2005

ATLAS AMERICA SERIES 25-2004 A L P (CIK 0001283810)
Date: July 13, 2005 · CIK: 0001283810 · Accession: 0000950116-05-002443

AI Filing Summary & Sentiment

Date
July 14, 2005
Author
Not clearly detected
Form
CORRESP
Company
ATLAS AMERICA SERIES 25-2004 A L P (CIK 0001283810)

Letter

July 14, 2005 ELECTRONIC FILING ----------------- Ms. Carmen Moncada-Terry Securities and Exchange Commission Mail Stop 0405 450 Fifth Street N. W. Washington, DC 20549

RE: Atlas America Series 25-2004(A) L.P. Registration Statement on Form 10 Filed April 29, 2005 File No. 0-51271 ------------------------------------

Dear Ms. Moncada-Terry:

Pursuant to your request during our telephone conference today, enclosed for your review is a revision of the second bullet point on page 2 of the Form 10 Registration Statement for the above-referenced partnership. Although not requested, I have also enclosed for your review a revision of the second bullet point on page 3 of the Form 10 Registration Statement, which I believe is consistent with respect to your comments concerning the second bullet point on page 2 as discussed above.

Please direct your comments concerning the enclosure to the undersigned.

Very truly yours,
KUNZMAN & BOLLINGER, INC.

Show Raw Text
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                            KUNZMAN & BOLLINGER, INC.
                                ATTORNEYS-AT-LAW
                          5100 N. BROOKLINE, SUITE 600
                          OKLAHOMA CITY, OKLAHOMA 73112
                            Telephone (405) 942-3501
                               Fax (405) 942-3527

                                  July 14, 2005

ELECTRONIC FILING
-----------------

Ms. Carmen Moncada-Terry
Securities and Exchange Commission
Mail Stop 0405
450 Fifth Street N. W.
Washington, DC 20549

         RE: Atlas America Series 25-2004(A) L.P.
             Registration Statement on Form 10
             Filed April 29, 2005
             File No. 0-51271
             ------------------------------------

Dear Ms. Moncada-Terry:

         Pursuant to your request during our telephone conference today,
enclosed for your review is a revision of the second bullet point on page 2 of
the Form 10 Registration Statement for the above-referenced partnership.
Although not requested, I have also enclosed for your review a revision of the
second bullet point on page 3 of the Form 10 Registration Statement, which I
believe is consistent with respect to your comments concerning the second bullet
point on page 2 as discussed above.

         Please direct your comments concerning the enclosure to the
undersigned.

                                                     Very truly yours,

                                                     KUNZMAN & BOLLINGER, INC.

                                                     /s/ Gerald A. Bollinger

                                                     Gerald A. Bollinger

Enclosure

cc:  Mr. Freddie Kotek
     Ms. Nancy McGurk
     Ms. Carmen Moncada-Terry

<PAGE>

                THE FOLLOWING IS THE SECOND BULLET POINT ON PAGE

                     2 OF THE FORM 10 REGISTRATION STATEMENT
                     ---------------------------------------

o    Obtain federal income tax deductions in 2004 from intangible drilling costs
     in an amount equal to not less than 90% of each participant's subscription
     price for his or her Units. However, we do not guarantee the IRS treatment
     of our participants' deductions for intangible drilling costs. If the IRS
     were to decrease the amount of the deduction, or defer part of the
     deduction to 2005 for wells we prepaid in 2004, for example, our
     participants would not be entitled to any reimbursement from us for any
     increase in taxes owed, penalties or interest or any other lost tax
     benefits. Subject to any objections by the IRS, each participant's
     individual tax circumstances, and the passive activity rules if the
     participant invested as a limited partner, these deductions for intangible
     drilling costs may be used to offset a portion of the participant's taxable
     income. For example, if a participant paid $25,000 for a Unit the
     investment would produce a 2004 tax deduction of not less than $22,500 per
     unit, 90%, against:

     o   ordinary income, or capital gain in some situations, if the participant
         invested as an investor general partner; and

     o   passive income if the participant invested as a limited partner.

     In the first quarter of 2005, our IRS Schedule K-1's to our participants
     reported a deduction for intangible drilling costs in 2004 in an amount
     equal to 90% of the subscription price paid by each participant. As
     discussed above, however, we do not guarantee the IRS treatment of our
     participants' deductions for intangible drilling costs.

                THE FOLLOWING IS THE SECOND BULLET POINT ON PAGE

                     3 OF THE FORM 10 REGISTRATION STATEMENT
                     ---------------------------------------

o    Provide each of our participants with tax deductions, in an aggregate
     amount which equals the remaining 10% of the participant's initial
     investment, through annual depreciation deductions over a seven-year cost
     recovery period. However, we do not guarantee the IRS treatment of our
     participants' depreciation deductions for our equipment costs. If the IRS
     were to decrease the amount of the deductions, for example, our
     participants would not entitled to any reimbursement from us for any
     increase in taxes owed, penalties or interest or any other lost tax
     benefits. In addition to any objections by the IRS, the tax benefits of
     these depreciation deductions to our participants are subject to each
     participant's individual tax circumstances and the passive activity rules
     if the participant invested as a limited partner.

</TEXT>
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