SEC Comment Letter for IEH Corp (IEHC) (CIK 0000050292) (IEHC) — Jan 14, 2020
IEH Corp (IEHC) (CIK 0000050292)
Date: Jan. 14, 2020 · CIK: 0000050292 · Accession: 0000000000-20-000319
AI Filing Summary & Sentiment
File numbers found in text: 000-05278
Letter
January 13, 2020 Robert Knoth Chief Financial Officer IEH Corporation 140 58th Street, Suite 8E Brooklyn, New York 11220 Re:IEH Corporation Form 10-K for the Fiscal Year Ended March 29, 2019 Filed July 12, 2019 File No. 000-05278 Dear Mr. Knoth: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 29, 2019 Management's Report on Internal Control over Financial Reporting, page 23 1.Please include disclosure in your future filings of the COSO framework (e.g. 2013) used to evaluate the effectiveness of your internal control over financial reporting. Item 9A. Controls and Procedures Changes in Internal Control over Financial Reporting, page 24 2.Please refer to Item 308(C) of Regulation S-K and provide disclosure of whether or not any changes occurred during your last fiscal quarter, that materially affected or is reasonably likely to materially affect your internal control over financial reporting. It is unclear from your disclosure if the changes you mention were implemented in your last fiscal quarter or at other times. We note your disclosure indicates the Audit Committee
FirstName LastNameRobert Knoth Comapany NameIEH Corporation January 13, 2020 Page 2 FirstName LastNameRobert Knoth IEH Corporation January 13, 2020 Page 2 was formed on November 27, 2018, which appears to represent a change in your third fiscal quarter. Financial Statements Report of Independent Registered Public Accounting Firm , page 39 3.Please have your independent registered public accounting firm provide you with an audit opinion that provides audit coverage for the years ended March 29, 2019 and March 30, 2018. Please file an amendment to include the revised report along with updated certifications. Refer to Rule 8-02 of Regulation S-X for guidance. Balance Sheet, page 40 4.We note that you reflect $54,489 in other assets on your balance sheet for both fiscal years ended 2019 and 2018. Please explain to us what this asset represents and why the balance remains unchanged. Liabilities and Stockholders' Equity, page 41 5.We note $348,230 of "Customer advance payments" as of March 29, 2019 reflected on your balance sheet. Please explain to us the nature of the advance payments. As part of your response, please explain to us why the disclosure requirements under ASC 606-10- 50-8 are not applicable. Notes to Financial Statements Note 7 Income Taxes, page 50 6.You disclosed that your company accounts for deferred income tax assets or liabilities under ASC 740. Please address the following:
•Please revise to disclose the components of the net deferred tax liability or asset in accordance with paragraphs 2 through 5 of ASC 740-10-50. •Please explain to us where on the balance sheet you recorded deferred tax assets and deferred tax liabilities. •Please disclose a reconciliation using percentages or dollar amounts of the reported amount of income tax expense attributable to continuing operations for the year to the amount of income tax expense that would result from applying domestic federal statutory tax rates. Refer to ASC 740-10-50-12.
FirstName LastNameRobert Knoth Comapany NameIEH Corporation January 13, 2020 Page 3 FirstName LastName Robert Knoth IEH Corporation January 13, 2020 Page 3 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at 202-551-3723 if you have questions regarding comments. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
January 13, 2020
Robert Knoth
Chief Financial Officer
IEH Corporation
140 58th Street, Suite 8E
Brooklyn, New York 11220
Re:IEH Corporation
Form 10-K for the Fiscal Year Ended March 29, 2019
Filed July 12, 2019
File No. 000-05278
Dear Mr. Knoth:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 29, 2019
Management's Report on Internal Control over Financial Reporting, page 23
1.Please include disclosure in your future filings of the COSO framework (e.g. 2013) used
to evaluate the effectiveness of your internal control over financial reporting.
Item 9A. Controls and Procedures
Changes in Internal Control over Financial Reporting, page 24
2.Please refer to Item 308(C) of Regulation S-K and provide disclosure of whether or not
any changes occurred during your last fiscal quarter, that materially affected or is
reasonably likely to materially affect your internal control over financial reporting. It is
unclear from your disclosure if the changes you mention were implemented in your last
fiscal quarter or at other times. We note your disclosure indicates the Audit Committee
FirstName LastNameRobert Knoth
Comapany NameIEH Corporation
January 13, 2020 Page 2
FirstName LastNameRobert Knoth
IEH Corporation
January 13, 2020
Page 2
was formed on November 27, 2018, which appears to represent a change in your third
fiscal quarter.
Financial Statements
Report of Independent Registered Public Accounting Firm , page 39
3.Please have your independent registered public accounting firm provide you with an audit
opinion that provides audit coverage for the years ended March 29, 2019 and March 30,
2018. Please file an amendment to include the revised report along with updated
certifications. Refer to Rule 8-02 of Regulation S-X for guidance.
Balance Sheet, page 40
4.We note that you reflect $54,489 in other assets on your balance sheet for both fiscal years
ended 2019 and 2018. Please explain to us what this asset represents and why the balance
remains unchanged.
Liabilities and Stockholders' Equity, page 41
5.We note $348,230 of "Customer advance payments" as of March 29, 2019 reflected on
your balance sheet. Please explain to us the nature of the advance payments. As part of
your response, please explain to us why the disclosure requirements under ASC 606-10-
50-8 are not applicable.
Notes to Financial Statements
Note 7 Income Taxes, page 50
6.You disclosed that your company accounts for deferred income tax assets or liabilities
under ASC 740. Please address the following:
•Please revise to disclose the components of the net deferred tax liability or asset in
accordance with paragraphs 2 through 5 of ASC 740-10-50.
•Please explain to us where on the balance sheet you recorded deferred tax assets and
deferred tax liabilities.
•Please disclose a reconciliation using percentages or dollar amounts of the reported
amount of income tax expense attributable to continuing operations for the year to the
amount of income tax expense that would result from applying domestic federal
statutory tax rates. Refer to ASC 740-10-50-12.
FirstName LastNameRobert Knoth
Comapany NameIEH Corporation
January 13, 2020 Page 3
FirstName LastName
Robert Knoth
IEH Corporation
January 13, 2020
Page 3
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at 202-551-3723 if
you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Manufacturing