SEC Comment Letter for TEJON RANCH CO (TRC) (CIK 0000096869) (TRC) — Nov 28, 2012
TEJON RANCH CO (TRC) (CIK 0000096869)
Date: Nov. 28, 2012 · CIK: 0000096869 · Accession: 0000000000-12-064350
AI Filing Summary & Sentiment
Letter
November 28, 2012 Via E -mail Allen E. Lyda Senior Vice President and Chief Financial Officer Tejon Ranch Co. P.O. Box 1000 Lebec, California 93243
Re: Tejon Ranch Co. Form 10 -K for fiscal y ear ended December 31, 2011 Filed March 12, 2012 File No. 1-7183
Dear Mr. Lyda:
We have reviewed your response dated November 7 , 2012 an d have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe o ur comment applies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment, we may have additional comments.
Form 10 -K for fiscal year ended Dece mber 31, 2011
Item 7. Management’ Discussion and Analysis of Financial Condition and Results of Operations, page 23
Results of Operations by Segment, page 28
Real Estate – Resort/Residential, page 30 We have reviewed your response to comment number 1. Please tell us what the expected 1. period of performance is given that you have a commitment not to perform any development on the property. Additionally, please tell us what would happen if the property was sold to a third party. Specifically, tell us whe ther a new owner would be subject to the easement.
Allen E. Lyda Tejon Ranch Co. November 28, 2012 Page 2
You may contact Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at 202.551.3629 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Kevin Woody
Show Raw Text
November 28, 2012 Via E -mail Allen E. Lyda Senior Vice President and Chief Financial Officer Tejon Ranch Co. P.O. Box 1000 Lebec, California 93243 Re: Tejon Ranch Co. Form 10 -K for fiscal y ear ended December 31, 2011 Filed March 12, 2012 File No. 1-7183 Dear Mr. Lyda: We have reviewed your response dated November 7 , 2012 an d have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe o ur comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10 -K for fiscal year ended Dece mber 31, 2011 Item 7. Management’ Discussion and Analysis of Financial Condition and Results of Operations, page 23 Results of Operations by Segment, page 28 Real Estate – Resort/Residential, page 30 We have reviewed your response to comment number 1. Please tell us what the expected 1. period of performance is given that you have a commitment not to perform any development on the property. Additionally, please tell us what would happen if the property was sold to a third party. Specifically, tell us whe ther a new owner would be subject to the easement. Allen E. Lyda Tejon Ranch Co. November 28, 2012 Page 2 You may contact Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at 202.551.3629 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Kevin Woody Kevin Woody Accounting Branch Chief