SEC Company Response from TNR TECHNICAL INC (CIK 0000723615) — Mar 22, 2005
TNR TECHNICAL INC (CIK 0000723615)
Date: March 22, 2005 · CIK: 0000723615 · Accession: 0001125282-05-001499
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[TNR TECHNICAL, INC. LOGO]
301 Central Park Drive
Sanford, FL 32771
(407) 321-3011
March 22, 2005
Mr. Eric Atallah
Staff Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington D.C. 20549
Subject: Response to Comment Letter, dated March 9, 2005
TNR Technical, Inc.
Dear Mr. Atallah:
We hereby submit our responses to your comment letter, dated March 9, 2005,
related to our Form 10-K/A (for the year ended July 31, 2004) and Form 10-Q (for
the quarter ended October 31, 2004) filings with respect to the request for
supplemental information in comments numbering 4-8.
COMMENTS 1-3: Comments 1 - 3 will be addressed in future filings in a
manner consistent with our recently filed Form 10-Q for the
quarter ended January 31, 2005.
COMMENT 4: In response to your inquiry, we herein supplementally
disclose that trading gains for the fiscal year ended July 31,
2004 associated with trading securities still held at the
balance sheet date amounted to $47,670 net of money market
interest and realized gains/losses. In accordance with your
instructions, we will in future filings disclose this
information in the notes to the financial statements.
COMMENT 5: We agree with your comment regarding the appropriate
classification of the purchase of investments within the
statement of cash flows. We have inadvertently classified
these purchases as investing activities and agree that they
should be displayed as an operating activity. Accordingly, in
future filings we will classify purchases of investments as an
operating activity and reclassify purchases in prior periods
to be consistent with the proper presentation as discussed
herein.
COMMENT 6: Inventories are valued and stated in the financial
statements at the lower of cost (as determined by the
first-in, first-out method) or market. Finished products
(including work in progress) represent assembled products
which are generally minimal with respect to inventory balances
taken as a whole. These products, which are substantially
produced on a made-to-order basis, include all direct costs,
such as labor and materials and those indirect costs which are
related to production, such as indirect labor, supplies and
warehousing costs. Reserves, if any, are very minimal and
relate primarily to discontinued product lines when they do
occur. We will revise future filings to expand our disclosure
regarding the valuation of inventories as indicated herein.
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Mr. Eric Atallah
March 22, 2005
Page 2 of 3
COMMENT 7: We have noted your comment related to the lease arrangement
we have with a related party. We will revise future filings to
disclose the amount due to related parties as of the balance
sheet. For the fiscal year ended July 31, 2004, there were no
amounts due to related parties as of that date. The lease
agreement was executed and commenced in 1996. Therefore, our
disclosure of future lease payments runs through the end of
the current lease agreement which is in the fiscal year ending
2006. There is no indication in this agreement of the
existence of any renewal provisions.
COMMENT 8: We agree with your comment and will in future filings
reflect losses on the sale or disposition of fixed assets
within operating income and reclassify prior year reported
amounts to be consistent with this treatment.
COMMENTS 9-12: We believe the answers to these comments would cause
immaterial changes to the prior filings. We would like to
comply with these comments in future filings. Moreover, we
complied with these comments in the recently filed Form 10-Q
for TNR's quarter ended January 31, 2005.
Please let us know if you have any questions regarding our responses or require
further information.
Very truly yours,
/s/ Wayne Thaw
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Wayne Thaw
President
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