alpn-income_corresp.htm
Alpine
Income Trust
2500
Westchester Avenue, Suite 215
Purchase,
NY 10577-2540
January
20, 2010
VIA
EDGAR TRANSMISSION
Ms.
Sheila Stout
Securities
and Exchange Commission
Division
of Investment Management
100 “F”
Street, N.E.
Washington,
DC 20549
Re: ALPINE INCOME TRUST (the
“Trust”)
1933 Act Registration File No.
333-100289
1940 Act
File No. 811-21210
Alpine
Municipal Money Market Fund - S000005211
Dear Ms.
Stout:
This correspondence is being filed in
response to the oral comments we understand were given to U.S. Bancorp Fund
Services, LLC (“U.S. Bancorp”), the Administrator of the Trust, on January 7,
2010 regarding the review of the Trust’s four most recent semi-annual reports
for registered investment companies filed on Form N-SAR, dated October 31, 2009,
April 30, 2009, October 31, 2008 and April 30, 2008, specifically with regard to
the Alpine Municipal Money Market Fund (the “Fund”).
For your convenience, the comment we
understand was given by the Staff of the Securities and Exchange Commission (the
“Commission” or the “Staff”) has been reproduced in bold typeface immediately
followed by the Trust’s responses.
Staff
Comment: Please either confirm the accuracy of the response
“1.0000” to Item 74W on each of the Trust’s Form N-SARs mentioned above, or note
the error(s) and explain the reason for such error(s), in addition to providing
the correct response. If applicable, please file an amended Form
N-SAR report.
Response:
The Trust
responds by noting that Item 74W regarding the mark-to market net asset value
per share for money market funds indicates that only four decimal places be used
in the response. For each of the semi-annual periods noted above, the
extended net asset value for the Alpine Municipal Money Market Fund, using
generally accepted accounting principles and rounding this number to four
decimal places results in a net asset value per share of $1.0000 in each
instance, except for the report on Form N-SAR dated October 31,
2009. Therefore, the Trust confirms that the Form N-SAR filings dated
April 30, 2009, October 31, 2008 and April 30, 2008 have displayed the correct
net asset value per share for the Alpine Municipal Money Market
Fund. With respect to the Form N-SAR for the Fund dated October 31,
2009, the response to Item 74W should be $1.0001, rather than
$1.0000. The originally filed Form N-SAR contained the incorrect
response due to the failure by U.S. Bancorp, third party service provider to the
Trust, to perform quality control checks against U.S. Bancorp supporting
documentation. An amended Form N-SAR filing will be completed by the
Trust, on behalf of the Fund, for the semi-annual period ending October 31,
2009.
The Trust
relies on U.S. Bancorp for these NAV calculations and does not independently
compute them. Given the importance of the accuracy of NAV
calculations, the Trust has reviewed with U.S. Bancorp personnel the reasons for
this error and steps taken to avoid a reoccurrence, including the institution of
procedural controls for the drafting of all Form N-SARs.
In connection with this response to the
Staff’s comments, the Trust, on behalf of the Fund, hereby states the
following:
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(1)
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The
Fund acknowledges that in connection with the comments made by the Staff
regarding semi-annual reports for registered investment companies filed on
Form N-SAR, the Staff has not passed generally on the accuracy or adequacy
of the disclosure made in the
reports;
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(2)
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The
Fund acknowledges that 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 filings;
and
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(3)
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The
Fund represents that it will not assert the Staff’s review process as a
defense in any action by the Commission or any securities-related
litigation against the Fund.
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If you have any questions regarding the
enclosed, please do not hesitate to contact Rachel A. Spearo of U.S. Bancorp
Fund Services, LLC at (414) 765-5384.
Very
truly yours,
ALPINE
INCOME TRUST
/s/ Ronald G. Palmer,
Jr.
Ronald G.
Palmer, Jr.
Chief
Financial Officer
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