BIGGEST LITTLE INVESTMENTS, L.P.
3702 S. Virginia St., Unit G2
Reno, NV 89502
Tel:775-825-3355
Fax:775-825-9928
January 21, 2011
Via EDGAR
Jorge Bonilla
Senior Staff Accountant
US Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
We are in receipt of your letter dated January 20, 2011, containing
your comment (the "Second Comment Letter") to our response to your
January 12, 2011 letter with respect to our Annual Report on Form 10-K
for the year ended December 31, 2009. Following is our response to the
Second Comment Letter:
Given the real estate market conditions in Reno, Nevada, fair
market value determination is extremely subjective. Therefore, the
Partnership has looked to third party assessments in evaluating
whether impairment is needed. The Washoe County Tax Assessor has
valued the Sierra Property every year per the following schedule:
Roll Year Total Taxable Value
--------- -------------------
2011 $18,157,644
2010 18,143,459
2009 19,511,000
2008 20,831,353
2007 20,223,965
Please also note that another government agency recently made an
offer to purchase a small portion of the Sierra Property at a price
which suggests that no impairment is needed. Please refer to the
Form 8-K filed by the Partnership on January 18, 2011, regarding
this offer.
The Partnership is responsible for the adequacy and accuracy of the
disclosure in its filings. The Partnership acknowledges that 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 the Partnership 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.
Sincerely yours,
Biggest Little Investments, L.P.
/s/ BEN FARAHI
--------------
Ben Farahi
Manager of the General Partner