October 26, 2005

Via Facsimile (925) 871-4046 and U.S. Mail
Chip Patterson, Esq.
MacKenzie Patterson Fuller, Inc.
1640 School Street
Moraga California 94556
(925) 631-9100 ext 206

Re:	Concord Milestone Plus, L.P.
Schedule TO filed October 13, 2005 by MacKenzie Patterson Fuller,
Inc. et al.
      SEC File No. 005- 81005


Dear Mr. Patterson:

      We have reviewed the above-referenced filing and have the
following comments.  Please make corresponding changes, where
applicable, to the filing in response to these comments.
Schedule TO-T
Section 13.  Conditions of the Offer, page 18
1. We note your reference to the "prospects" of the purchaser and
the
partnership. We are concerned that your offer condition is drafted
so
broadly and generally as to make it difficult to determine whether
it
has been "triggered" by events as they occur.   Please revise to
specify or generally describe the prospects to which you refer in
this section so that security holders will have the ability to
objectively determine whether the condition has been triggered.

2. In addition, we note the first condition refers to the
business,
properties, assets, liabilities, financial condition, operations
and
results of operations of the Purchasers.  Since the Purchasers are
not reporting companies and little information is available about
them, it is unclear how a security holder could objectively verify
the triggering of the condition.  Please revise your document so
security holders can objectively verify all of the bases upon
which
you may terminate the offer.

3. We note your statement on page 19, regarding the conditions,
that
"[a]ny determination by the Purchasers concerning the events
described above will be final and binding upon all parties."
Please
revise this sentence to more precisely define its scope.  It
appears
that your interpretation of the terms of the tender offer may not
necessarily be final and binding on all parties.  For example,
while
you may assert an offer condition when it is triggered, when
parties
contest asserted conditions, the judgments of courts of law are
generally considered final and binding in such matters.
Closing Comments

	In connection with responding to our comments, please
provide,
in writing, a statement from all filing persons acknowledging
that:

* you are 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
* you 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 comments on your filing.

      As appropriate, please amend your documents in response to
these comments.  You may wish to provide us with marked copies of
the
amendment, if required, to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.  In addition, depending upon your response to these
comments, a supplement may need to be sent to security holders.

      Please direct any questions to me at (202) 551-3345 or by
facsimile at (202) 772-9203.

      						Very truly yours,



							Michael Pressman
							Special Counsel
							Office of Mergers
and Acquisitions

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Chip Patterson, Esq.
MacKenzie Patterson Fuller, Inc.
October 26, 2005
Page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0303

         DIVISION OF
CORPORATION FINANCE