SEC Comment Letter for GENUINE PARTS CO (GPC) (CIK 0000040987) (GPC) — May 10, 2006
GENUINE PARTS CO (GPC) (CIK 0000040987)
Date: May 10, 2006 · CIK: 0000040987 · Accession: 0000000000-06-022245
AI Filing Summary & Sentiment
File numbers found in text: 001-05690
Referenced dates: April 20, 2006
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 3651
May 9, 2006
Via U.S. Mail and Facsimile
Thomas C. Gallagher
Chief Executive Officer
Genuine Parts Company
2999 Circle 75 Parkway
Atlanta, Georgia 30339
RE: Genuine Parts Company
Form 10-K for the Fiscal Year Ended December 31,
2005
File No. 001-05690
Dear Mr. Gallagher:
We have reviewed your response letter dated April 20, 2006
and
have the following comments. Where indicated, we think you should
revise your future filings in response to these comments. If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation. In our comment, we may ask you to
provide us with information so we may better understand your
disclosure. After reviewing this information, we may raise
additional comments.
We look forward to working with you in these respects. We
welcome any questions you may have about our comment or any other
aspect of our review. Feel free to call us at the telephone
numbers
listed at the end of this letter.
Form 10-K for the fiscal year ended December 31, 2005
Exhibit 13
Note. 4
1. We note your response to our prior comment 6. In addition to
your
future proposed disclosures, please tell us and disclose in your
future filing the line item under which the total amount of
approximately $83,880,000 related to your construction and lease
facility advance payments at December 31, 2005 is reflected in
your
financial statements. Also, please provide the amortization
period
and methods used in recognizing your expense.
As appropriate, please amend your future filings and respond
to
this comment within 10 business days or tell us when you will
provide
us with a response. Please furnish a cover letter that keys your
responses to our comment and provides any requested information.
Detailed cover letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing
your
responses to our comments.
You may contact Jeff Jaramillo at (202) 551-3212 or Lyn
Shenk,
Assistant Chief Accountant, at (202) 551-3380 if you have
questions
regarding comments on the financial statements and related
matters.
Please contact Max Webb, Assistant Director, at (202) 551-3755
with
any other questions.
Sincerely,
Linda Cvrkel
Branch Chief
Via facsimile: Jerry W. Nix, Chief Financial Officer
(770) 956-2207
Thomas C. Gallagher
Genuine Parts Company
May 9, 2006
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