SEC Comment Letter for TIPPERARY CORP (CIK 0000098410) — Sep 9, 2005
TIPPERARY CORP (CIK 0000098410)
Date: Sept. 9, 2005 · CIK: 0000098410 · Accession: 0000000000-05-046652
AI Filing Summary & Sentiment
File numbers found in text: 001-07796
Referenced dates: September 6, 2005
Letter
September 9, 2005 Mr. Joseph B. Feiten Chief Financial Officer Tipperary Corporation 633 Seventeenth Street, Suite 1550 Denver, Colorado 80202
Re: Tipperary Corporation Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 24, 2005 Response Letter Dated September 6, 2005 File No. 001-07796
Dear Mr. Feiten:
We have reviewed your response letter and have the following comment. We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to our comment. 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 some of our comments, 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.
Form 10-K for the Fiscal Year Ended December 31, 2004
Engineering Comment
Estimates of Oil and Gas Reserves (Unaudited), page 56
1. Regarding your response number 5, monetization of the reserves booked in 2004 will not begin for approximately 10 years while the monetization of reserves booked in 2003 will begin in 2009. Please provide the basis for declaring these reserves to be proved at this time and explain to us the gas market that exists for possible monetization of these reserves sooner. Describe to us the approved gas contracts that you have in place for both the reserves added in 2003 and 2004, including the annual volumes to be delivered and sold, the purchasers of the gas and the gas price you will receive.
Closing Comments
As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact James Murphy, Petroleum Engineer, at (202) 551- 3703 with questions about engineering comments. Please contact me at (202) 551-3740 with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
September 9, 2005
Mr. Joseph B. Feiten
Chief Financial Officer
Tipperary Corporation
633 Seventeenth Street, Suite 1550
Denver, Colorado 80202
Re: Tipperary Corporation
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 24, 2005
Response Letter Dated September 6, 2005
File No. 001-07796
Dear Mr. Feiten:
We have reviewed your response letter and have the following
comment. We have limited our review of your filing to those
issues
we have addressed in our comments. Where indicated, we think you
should revise your document in response to our comment. 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 some of our comments, 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.
Form 10-K for the Fiscal Year Ended December 31, 2004
Engineering Comment
Estimates of Oil and Gas Reserves (Unaudited), page 56
1. Regarding your response number 5, monetization of the reserves
booked in 2004 will not begin for approximately 10 years while the
monetization of reserves booked in 2003 will begin in 2009.
Please
provide the basis for declaring these reserves to be proved at
this
time and explain to us the gas market that exists for possible
monetization of these reserves sooner. Describe to us the
approved
gas contracts that you have in place for both the reserves added
in
2003 and 2004, including the annual volumes to be delivered and
sold,
the purchasers of the gas and the gas price you will receive.
Closing Comments
As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please understand that we may have additional comments after
reviewing your response to our comment.
You may contact James Murphy, Petroleum Engineer, at (202)
551-
3703 with questions about engineering comments. Please contact me
at
(202) 551-3740 with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
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Mr. Joseph B. Feiten
Tipperary Corporation
September 9, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
</TEXT>
</DOCUMENT>