0000318835-11-000001.txt : 20110412
0000318835-11-000001.hdr.sgml : 20110412
20110112190453
ACCESSION NUMBER: 0000318835-11-000001
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20110112
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: DSI REALTY INCOME FUND VI
CENTRAL INDEX KEY: 0000318835
STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE [6500]
IRS NUMBER: 953633566
STATE OF INCORPORATION: CA
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 6700 E. PACIFIC COAST HWY
STREET 2: SUITE 150
CITY: LONG BEACH
STATE: CA
ZIP: 90803
BUSINESS PHONE: 562 493-8881
MAIL ADDRESS:
STREET 1: P.O. BOX 357
CITY: LONG BEACH
STATE: CA
ZIP: 90801
FORMER COMPANY:
FORMER CONFORMED NAME: DSI REALTY INCOME FUND 81-I
DATE OF NAME CHANGE: 19870812
CORRESP
1
filename1.txt
Via Edgar
January 12, 2011
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington DC, 20549
ATTN: Robert Telewicz, Senior Staff Accountant
Howard Efron, Staff Accountant
Re: DSI Realty Income Funds
Form 10-K for Fiscal Year Ended December 31, 2009
Gentlemen:
I am writing on behalf of DSI Realty Income Fund VI (File No. 002-68926), DSI
Realty Income Fund VII (File No. 002-83291), DSI Realty Income Fund VIII (File
No. 002-90168), DSI Realty Income Fund IX (File No. 000-14186), DSI Realty
Income Fund X (File No. 000-15346), DSI Realty Income Fund XI (File No.
000-18286),which are collectively the "DSI Realty Income Funds", in response to
a letter of comment from the staff of the Securities and Exchange Commission
(the "Staff") dated December 30, 2010 (the "Staff Letter").
We confirm that we had received a manually signed audit report from the auditors
with an opinion date of March 31, 2010.
In your letter you state there are inconsistencies of our position
designations. Per the Staff's recommendations we have revised our Item 10 to
include bio information of Richard P. Conway with the position designation of
chief financial officer, have revised the information of Robert J. Conway to
include his current position designation of chief executive officer and
revised the Form 10-K signature page to include Richard P. Conway into our
current 10-K for the period ended December 31, 2010. We will incorporate
these changes into all future filings.
In your letter you state for DSI Realty Income Fund XI: "Explain to us where
you have classified noncontrolling interests on your consolidated balance
sheets."
Noncontrolling interests are classified as part of total equity. The portions
of net income allocated to noncontrolling interest are fully distributed prior
to year end. As a result the carrying amount on the balance sheets is zero.
This is detailed in the consolidated statements of changes in partners'
equity (deficit).
DSI Realty Income Funds acknowledges that:
* DSI Realty Income Funds are responsible for the adequacy and accuracy of the
disclosure in the filing;
* Staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings;and
* DSI Realty Income Funds 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.
Please direct comments and/or any questions you may have to me or
Richard P. Conway, Chief Financial Officer at (562) 493-3022.
Sincerely,
/s/ ROBERT J. CONWAY
__________________________________
Robert J. Conway
Chief Executive Officer
January 12, 2011