SEC Comment Letter for PENN VIRGINIA CORP (CIK 0000077159) — Jun 27, 2005
PENN VIRGINIA CORP (CIK 0000077159)
Date: June 27, 2005 · CIK: 0000077159 · Accession: 0000000000-05-032642
AI Filing Summary & Sentiment
Referenced dates: June 1, 2005, June 13, 2005
Letter
June 23, 2005 Frank A. Pici Executive Vice President and Chief Financial Officer Penn Virginia Corporation Three Radnor Corporate Center, Suite 230 100 Matsonford Road Radnor, PA 19087
Re: Penn Virginia Corporation Form 10-K for Fiscal Year Ended December 31, 2004 Filed on March 11, 2005 Response Letter Dated June 13, 2005 File number 1-13283
Dear Mr. Pici:
We have reviewed your response letter and have the following comment. Our review has been limited to those matters specifically addressed in this letter and the letter dated June 1, 2005. As indicated, we think you should file a Form 8-K in response to our comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or filing a Form 8-K is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2004
Financial Statements, page 51
Note 4 - Acquisitions, page 65
Coal Royalty and Land Management, page 65
1. We have considered your response to our comment two in our letter dated June 1, 2005; however, given the significance of this acquisition to your financial statements, which include the consolidated financial statements of Penn Virginia Resource Partners, L.P., we continue to believe you should file a Form 8-K that includes the historical financial statements of Cantera Natural Gas LLC and related pro forma financial information. Although you followed the precise language of Item 2.01 of Form 8-K, which is applicable to "the registrant or any of its majority-owned subsidiaries," we believe this Item also applies to consolidated subsidiaries. We consider this financial information relevant to investors for purposes of understanding how this acquisition will impact your future operations.
Closing Comments
As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response.
You may contact Yong Choi at (202) 551-3758 or Jenifer Gallagher at (202) 551-3706 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3684 with any other questions.
Sincerely,
April Sifford
Branch Chief
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<DOCUMENT>
<TYPE>LETTER
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<FILENAME>filename1.txt
<TEXT>
June 23, 2005
Frank A. Pici
Executive Vice President and Chief Financial Officer
Penn Virginia Corporation
Three Radnor Corporate Center, Suite 230
100 Matsonford Road
Radnor, PA 19087
Re: Penn Virginia Corporation
Form 10-K for Fiscal Year Ended December 31, 2004
Filed on March 11, 2005
Response Letter Dated June 13, 2005
File number 1-13283
Dear Mr. Pici:
We have reviewed your response letter and have the following
comment. Our review has been limited to those matters
specifically
addressed in this letter and the letter dated June 1, 2005. As
indicated, we think you should file a Form 8-K in response to our
comment. If you disagree, we will consider your explanation as to
why
our comment is inapplicable or filing a Form 8-K is unnecessary.
Please be as detailed as necessary in your explanation. After
reviewing this information, we may raise additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2004
Financial Statements, page 51
Note 4 - Acquisitions, page 65
Coal Royalty and Land Management, page 65
1. We have considered your response to our comment two in our
letter
dated June 1, 2005; however, given the significance of this
acquisition to your financial statements, which include the
consolidated financial statements of Penn Virginia Resource
Partners,
L.P., we continue to believe you should file a Form 8-K that
includes
the historical financial statements of Cantera Natural Gas LLC and
related pro forma financial information. Although you followed
the
precise language of Item 2.01 of Form 8-K, which is applicable to
"the
registrant or any of its majority-owned subsidiaries," we believe
this
Item also applies to consolidated subsidiaries. We consider this
financial information relevant to investors for purposes of
understanding how this acquisition will impact your future
operations.
Closing Comments
As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
You may contact Yong Choi at (202) 551-3758 or Jenifer
Gallagher
at (202) 551-3706 if you have questions regarding comments on the
financial statements and related matters. Please contact me at
(202)
551-3684 with any other questions.
Sincerely,
April Sifford
Branch Chief
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Frank A. Pici
Penn Virginia Corporation
June 23, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
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