Quarterly Report — Form 10-Q Filing Table of Contents
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1: 10-Q Quarterly Report HTML 794K
2: EX-10.36 Material Contract HTML 265K
3: EX-10.37 Material Contract HTML 11K
4: EX-10.38 Material Contract HTML 6K
5: EX-10.39 Material Contract HTML 148K
6: EX-18 Letter re: Change in Accounting Principles HTML 11K
7: EX-31.1 Certification per Sarbanes-Oxley Act (Section 302) HTML 17K
8: EX-31.2 Certification per Sarbanes-Oxley Act (Section 302) HTML 17K
9: EX-32.1 Certification per Sarbanes-Oxley Act (Section 906) HTML 11K
10: EX-32.2 Certification per Sarbanes-Oxley Act (Section 906) HTML 10K
EX-18 — Letter re: Change in Accounting Principles
We have
been furnished with a copy of the quarterly report on Form 10-Q of Pope
Resources LP, A Delaware Limited Partnership (the “Company”) for the three
months ended September 30, 2009, and have read the Company’s statements
contained in Note 6 to the consolidated financial statements included
therein. As stated in Note 6, the Company changed its method of
accounting for the classification of cash outflows associated with real estate
development capital expenditures from investing activities to operating
activities within the consolidated statement of cash flows and states that the
newly adopted accounting principle is preferable in the circumstances because
the Company believes that cash inflows and cash outflows related to land held
for sale and land held for development should be classified in a consistent
manner and that classification within operating activities better reflects the
fact that these cash outflows are directly related to the Company’s operations
of developing and selling real estate. In accordance with your
request, we have reviewed and discussed with Company officials the circumstances
and business judgment and planning upon which the decision to make this change
in the method of accounting was based.
We have
not audited any financial statements of the Company as of any date or for any
period subsequent to December 31, 2008, nor have we audited the information set
forth in the aforementioned Note 6 to the consolidated financial statements;
accordingly, we do not express an opinion concerning the factual information
contained therein.
With
regard to the aforementioned accounting change, authoritative criteria have not
been established for evaluating the preferability of one acceptable method of
accounting over another acceptable method. However, for purposes of
the Company’s compliance with the requirements of the Securities and Exchange
Commission, we are furnishing this letter.
Based on
our review and discussion, with reliance on management’s business judgment and
planning, we concur that the newly adopted method of accounting is preferable in
the Company’s circumstances.
Very
truly yours,
/s/ KPMG
LLP
KPMG
LLP
Seattle,
Washington
Dates Referenced Herein and Documents Incorporated by Reference
