CET Services, Inc.
12503 E. Euclid Drive, Unit 30
Centennial, Colorado 80111
Telephone (720)875-9115
Fax (720) 875-9114
August 26, 2005
Ms. Nili Shah, Accounting Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-7010
Re: CET Services, Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2004
Filed March 4, 2005
Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
SEC File No. 1-13852
Dear Ms. Shah:
This letter is being submitted in response to the comments included in your
letter dated August 10, 2005. These responses are numbered in accordance
with the numbered comments contained in your letter.
Form 10-KSB for the Fiscal Year ended December 31, 2004
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Consolidated Balance Sheet, page F-4
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1. Accrued construction expense of $271,196 as of December 31, 2004
and $331,328 as of March 31, 2005 are construction costs incurred
by the Company's general contractor who is building townhomes on
Sites II and III of our Westminster project. The contractor
invoices the Company on the 10th of the month for work completed
in the previous month. The Company and the construction lender
then conduct inspections to verify the accuracy of the billing
before payment from the Company's construction loan is approved.
Future filings will reflect the following disclosure which
clarifies the Company's accounting policy for accrued
construction expense:
"Accrued construction expense represents construction
costs that have been incurred but which have not yet
been paid from the Company's construction loan. The
accrual is estimated based on invoices received from
the Company's general contractor."
Note M - Legal, page F-17
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2. The Company evaluates its loss contingencies as of each reporting
date. As of the date of the Company's prior filings, management
determined that its loss contingency was remote. If this evalua-
tion remains the same at future dates, we anticipate that future
filings will reflect the following disclosure:
"Management believes that a material adverse effect on the
Company's financial position or results of operation as a
result of any pending litigation is remote."
3. As of the date of the Company's prior filings, the Company
evaluated the loss contingency for the labor billing rates to
the EPA in accordance with SFAS. No. 5 and we concluded that
the contingency was remote. If this evaluation remains the
same at future dates, we anticipate that future filings
will reflect the following disclosure:
"No loss provision has been made at December 31, 2005
relating to this matter, as management believes that
any material adverse effect on the Company's financial
position or results of operation is remote."
Although we have concluded that the contingency is remote, future
filings will also include a discussion of the loss contingency
as a critical accounting policy as it has the potential to have
a significant impact on the consolidated financial statements.
Form 10-QSB for the quarter ended March 31, 2005
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Note 10 - Notes Payable, page 6
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4. Future filings will include the material terms of the Company's
loan agreements. This disclosure was made in the Form 10-QSB for
the quarter ended June 30, 2005, filed on August 12, 2005.
Please be advised that the Company acknowledges that the Company is
responsible for the adequacy and accuracy of the disclosure in our filings.
The Company also 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 filing and that the Company 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 feel free to contact me if you have any questions or need any
additional information.
Sincerely,
CET Services, Inc.
By: /s/ Dale W. Bleck
Dale W. Bleck
Chief Financial Officer