SEC – ‘UPLOAD’ from 10/27/05 re: Tele Norte Celular Participacoes SA – ‘LETTER’

On:  Thursday, 10/27/05, at 9:16am ET   ·   Private-to-Public:  Filing ¶  –  Release Delayed to:  6/23/06   ·   Accession #:  0-5-54627

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Delayed-Release Comment or Other Letter from the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                   2±     9K 


Mail Stop 3561                                                                  

                                                October 25, 2005

Mr. Antonio Jose Ribeiro dos Santos                                             
Chief Executive Officer                                                         
Tele Norte Celular Participacoes S.A.                                           
SCN Quadra 4, Bloco B, Ed. Centro Empresarial Varig, Torre Oeste,               
Sala 702-A                                                                      
70714-000 Brasilia-DF, Brazil                                                   

Re:     Tele Norte Celular Participacoes S.A.                   
Form 20-F for Fiscal Year Ended December 31, 2004                   
Filed June 30, 2005                             
File No. 333-09514-09                           

Dear Mr. Santos:                                                                

We have reviewed your supplemental response letter dated            
August                                                                          
17, 2005 as well as your filing and have the following comments.                
As                                                                              
noted in our comment letter dated July 26, 2005, we have limited                
our                                                                             
review to your financial statements and related disclosures and do              
not intend to expand our review to other portions of your                       
documents.                                                                      

Form 20-F for Fiscal Year Ended December 31, 2004                               

Consolidated Statements of Operations and Comprehensive Income,                 
page                                                                            
F-6                                                                             

1. We are still considering your response to comment 5.                         

Note 15- Contingencies, page F-31                                               

(a) Tax Contingencies, page F-31                                                

2. We note your response to prior comment 6.  It is still unclear               
to                                                                              
us how you accounted for the release of the escrow deposit                      
relating                                                                        
to the State treasury.  Tell us the offsetting entry that you                   
recorded in conjunction with the reduction to the provision and                 
clarify how you originally accounted for and presented the                      
deposit.                                                                        
You may wish to provide example journal entries to illustrate your              
accounting for the deposits and its release.                                    

*    *    *    *                                                                

Please respond to these comments within 10 business days or         
tell us when you will provide us with a response.  You may contact              
Melissa Hauber, Staff Accountant, at (202) 551-3368 or Carlos                   
Pacho,                                                                          
Senior Assistant Chief Accountant, at (202) 551-3835 if you have                
questions regarding comments on the financial statements and                    
related                                                                         
matters.  Please contact me at (202) 551-3810 with any other                    
questions.                                                                      

                                                          Sincerely,

                                                             Larry Spirgel
                                                              Assistant Director

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Mr. Antonio Jose Ribeiro dos Santos                                             
Tele Norte Celular Participacoes S.A.                                           
October 25, 2005                                                                
Page 2                                                                          

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Release Delayed to:		6/23/06		CORRESP,  UPLOAD
Filed on:		10/27/05		UPLOAD
		10/25/05		UPLOAD
		8/17/05		CORRESP,  UPLOAD
		7/26/05		UPLOAD
		6/30/05		20-F,  UPLOAD
		12/31/04		20-F
				List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 6/30/05  Tele Norte Celular Participac… SA 20-F       12/31/04    7:1.1M                                   MZ Technologies/FA