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SEC Comment Letter for AUTONATION, INC. (AN) (CIK 0000350698) (AN) — Jan 19, 2006

AUTONATION, INC. (AN) (CIK 0000350698)
Date: Jan. 19, 2006 · CIK: 0000350698 · Accession: 0000000000-06-003047

AI Filing Summary & Sentiment

Referenced dates: December 20, 2005

Date
January 19, 2006
Author
William Choi
Form
UPLOAD
Company
AUTONATION, INC. (AN) (CIK 0000350698)

Letter

Mail Stop 3561 January 19, 2006 Mr. Michael J. Jackson Chairman and Chief Executive Officer AutoNation, Inc. 110 S.E. 6th Street Fort Lauderdale, FL 33301

Re: AutoNation, Inc. Form 10-K for the Fiscal Year Ended December 31, 2004 Filed February 24, 2005 File No. 0-13107

Dear Mr. Jackson:

We have reviewed your response letter filed on January 6, to our comment letter dated December 20, 2005 and have the following comments. Where indicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please provide a written response to our comments. 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

Financial Statement and Supplementary Data

Consolidated Statements of Cash Flows, page 46

1. We have reviewed your response to comment 1 in our letter dated December 20, 2005. Given the significance of the error in classification of cash flows please amend your filing, as well as your Form 10-Q for the quarterly period ending September 30, 2005, to present cash flows (used)/provided from non-manufacturer lenders in financing activities. Since Rule 5-02(19)(a) of Regulation S-X requires separate and clear display of amounts payable to trade creditors and amounts payable for borrowings, please also revise your balance sheet to reflect non-manufacturer lender payables as borrowings and manufacturer lender payables as trade creditor payables. In addition, please disclose the change in classification of cash flows from non-manufacturer lenders as a correction of an error in accordance with paragraph 37 of APB 20. Further, please also revise your footnote disclosure to further describe the mechanics of your floorplan payable arrangements, including how cash disbursements are processed and if you have discretion to receive cash directly from the lenders.

Notes to Consolidated Financial Statements

Consolidated Statements of Cash Flows, page 46

2. We have reviewed your response to comment 2 in our letter dated December 20, 2005 and reissue our comment. Please amend your most recent annual and quarterly filings to comply with our previous comment regarding the presentation of discontinued operations in your statements of cash flows.

As appropriate, please amend your filings and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendments to expedite our review. Please furnish a cover letter with your amendments that keys your responses to our comments and provides any requested information. Detailed response letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendments and responses to our comments.

You may contact Andrew Blume (Staff Accountant) at (202) 551- 3254 or William Thompson (Staff Accountant) at (202) 551-3344 if you have questions regarding the comment on the financial statements and related matters. Please contact me at (202) 551-3716 with any other questions.

Sincerely,
William Choi
Accounting Branch
Chief

Show Raw Text
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<TEXT>

Mail Stop 3561

									January 19, 2006

Mr. Michael J. Jackson
Chairman and Chief Executive Officer
AutoNation, Inc.
110 S.E. 6th Street
Fort Lauderdale, FL 33301

      Re:	AutoNation, Inc.
      Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed February 24, 2005
      File No. 0-13107

Dear Mr. Jackson:

	We have reviewed your response letter filed on January 6,
2006
to our comment letter dated December 20, 2005 and have the
following
comments.  Where indicated, we think you should revise your
documents
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please provide a written response to our
comments.
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

Financial Statement and Supplementary Data

Consolidated Statements of Cash Flows, page 46

1. We have reviewed your response to comment 1 in our letter dated
December 20, 2005.  Given the significance of the error in
classification of cash flows please amend your filing, as well as
your Form 10-Q for the quarterly period ending September 30, 2005,
to
present cash flows (used)/provided from non-manufacturer lenders
in
financing activities.  Since Rule 5-02(19)(a) of Regulation S-X
requires separate and clear display of amounts payable to trade
creditors and amounts payable for borrowings, please also revise
your
balance sheet to reflect non-manufacturer lender payables as
borrowings and manufacturer lender payables as trade creditor
payables.  In addition, please disclose the change in
classification
of cash flows from non-manufacturer lenders as a correction of an
error in accordance with paragraph 37 of APB 20.  Further, please
also revise your footnote disclosure to further describe the
mechanics of your floorplan payable arrangements, including how
cash
disbursements are processed and if you have discretion to receive
cash directly from the lenders.

Notes to Consolidated Financial Statements

Consolidated Statements of Cash Flows, page 46

2. We have reviewed your response to comment 2 in our letter dated
December 20, 2005 and reissue our comment.  Please amend your most
recent annual and quarterly filings to comply with our previous
comment regarding the presentation of discontinued operations in
your
statements of cash flows.

		As appropriate, please amend your filings and respond to
these comments within 10 business days or tell us when you will
provide us with a response.  You may wish to provide us with
marked
copies of the amendments to expedite our review.  Please furnish a
cover letter with your amendments that keys your responses to our
comments and provides any requested information.  Detailed
response
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendments and
responses to our comments.

      You may contact Andrew Blume (Staff Accountant) at (202)
551-
3254 or William Thompson (Staff Accountant) at (202) 551-3344 if
you
have questions regarding the comment on the financial statements
and
related matters.  Please contact me at (202) 551-3716 with any
other
questions.

								Sincerely,

									William Choi
									Accounting Branch
Chief

Mr. Michael J. Jackson
AutoNation, Inc.
January 19, 2006
Page 1

</TEXT>
</DOCUMENT>