SEC Comment Letter for SOUTHERN NATURAL GAS CO (CIK 0000092232) — Nov 10, 2005
SOUTHERN NATURAL GAS CO (CIK 0000092232)
Date: Nov. 10, 2005 · CIK: 0000092232 · Accession: 0000000000-05-057059
AI Filing Summary & Sentiment
Referenced dates: October 20, 2005, September 29, 2005
Letter
November 9, 2005 By Facsimile and U.S. Mail Mark Leland Chief Financial Officer El Paso Corporation 1001 Louisiana Street Houston, TX 77002
Re: Southern Natural Gas Company Form 10-K for the year ended December 31, 2004 Filed March 29, 2005 File No. 1-2745
Dear Mr. Leland:
We reviewed your responses to our prior comments on the above referenced filings as set forth in your letter dated October 20, 2005. Our review resulted in the following accounting comment.
Southern Natural Gas Company Form 10-K for the year ended December 31, 2004
1. We note your response to comment seven of our letter dated September 29, 2005. We note that you are appropriately amortizing the excess fair value over cost regarding your investment in Citrus. Explain to us how you determined the amortization period. We further note that you cumulatively adjusted the credit balance in 2004 related to the correction of an error for prior periods. Explain to us why you believe this was appropriate GAAP since you were already correcting a known error in your financial statements related to prior periods. Also, provide to us your detailed analysis of materiality. You may consult SAB Topic no. 99. Furthermore, provide to us a roll-forward of the deferred tax liability account associated with your investments in unconsolidated affiliates. We may have further comment.
As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR as a correspondence file.
If you have any questions regarding these comments, please direct them to Robert Babula, Staff Accountant, at (202) 551-3339 or, in his absence, to the undersigned at (202) 551-3841. Any other questions regarding disclosures issues may be directed to H. Christopher Owings, Assistant Director at (202) 551-3725.
Sincerely,
Michael Moran, Esq.
Branch Chief
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> Mail Stop 3561 November 9, 2005 By Facsimile and U.S. Mail Mark Leland Chief Financial Officer El Paso Corporation 1001 Louisiana Street Houston, TX 77002 Re: Southern Natural Gas Company Form 10-K for the year ended December 31, 2004 Filed March 29, 2005 File No. 1-2745 Dear Mr. Leland: We reviewed your responses to our prior comments on the above referenced filings as set forth in your letter dated October 20, 2005. Our review resulted in the following accounting comment. Southern Natural Gas Company Form 10-K for the year ended December 31, 2004 1. We note your response to comment seven of our letter dated September 29, 2005. We note that you are appropriately amortizing the excess fair value over cost regarding your investment in Citrus. Explain to us how you determined the amortization period. We further note that you cumulatively adjusted the credit balance in 2004 related to the correction of an error for prior periods. Explain to us why you believe this was appropriate GAAP since you were already correcting a known error in your financial statements related to prior periods. Also, provide to us your detailed analysis of materiality. You may consult SAB Topic no. 99. Furthermore, provide to us a roll-forward of the deferred tax liability account associated with your investments in unconsolidated affiliates. We may have further comment. As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR as a correspondence file. If you have any questions regarding these comments, please direct them to Robert Babula, Staff Accountant, at (202) 551-3339 or, in his absence, to the undersigned at (202) 551-3841. Any other questions regarding disclosures issues may be directed to H. Christopher Owings, Assistant Director at (202) 551-3725. Sincerely, Michael Moran, Esq. Branch Chief ?? ?? ?? ?? Mr. Mark Leland Southern Natural Gas Company November 9, 2005 Page 2 2 </TEXT> </DOCUMENT>