CORRESP 1 filename1.htm

[LETTERHEAD OF WIEN & MALKIN LLC]

 

 

 

 

 

 

August 31, 2007

 

 

BY U.S. Mail and FAX to (202) 772-9209

Ms. Cicely L. LaMothe

Branch Chief

Securities and Exchange Commission

Washington, D.C. 20549

Re: 250 West 57th St. Associates L.L.C.

Your File No. 000-02666

Form 10-K for the year ended December 31, 2006

Dear Ms. LaMothe:

We are responding to your August 1, 2007 letter as follows:

1. Contractual Obligations - We shall include the additional tabular information related to contractual obligations in future Form 10-K filings and significant changes in Form 10-Q filings in accordance with Regulation S-X and FR72.

2. Financial Statements and Notes - General - Currently, we do not have audited financial statements of the lessee for any period. However, we intend to file audited lessee financial statements as of December 31, 2007 and 2006 and for the years ended 2007, 2006 and 2005 in our Form 10-K for the year ending December 31, 2007.

Since we will be providing audited financial statements for 2006 and 2005 going forward, we are proposing to use our best efforts to file an amendment to our Form 10-K for the year ended December 31, 2006 within 90 days that would include audited financial statements of the lessee for only 2006 and 2005.

We have not engaged an independent auditor to examine those financial statements as of yet and we cannot estimate definitively the amount of time such an audit will take. We do not believe that the provision of audited financial statements for 2004 would be cost beneficial to the holders of participation units, especially when consideration is given to the extremely limited amount of transfers that have taken place historically in these units and the fact that we will not be filing any registration statements under the 1933 Act. We seek your concurrence with this proposal.

3. Item 9a. Controls and Procedures - The statement that controls were "adequate" was a typographical error. We concluded they were effective. We used the appropriate wording in each Form 10-Q that we filed during 2006 and will use the appropriate wording in future Form 10-K and from 10-Q filings.

In addition, we acknowledge:

1. We are responsible for the adequacy and accuracy of the disclosure in the filings with the Securities and Exchange Commission ("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 our filings; and

3. We 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.

If you have any question or desire additional information, please communicate with the undersigned.

Thank you.

Very truly yours,

 

/s/ Mark Labell

Mark Labell

Senior Vice President, Finance

ML:fm

Enc.

cc: Thomas N. Keltner, Jr.

Stuart J. Rappaport