SEC Comment Letter 0000000000-23-001432 to CASEYS GENERAL STORES INC (CASY) (CIK 0000726958) (CASY)
CASEYS GENERAL STORES INC (CASY) (CIK 0000726958)
Date: Feb. 10, 2023 · CIK: 0000726958 · Accession: 0000000000-23-001432
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File numbers found in text: 001-34700
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United States securities and exchange commission logo
February 10, 2023
Stephen Bramlage, Jr.
Chief Financial Officer
Casey’s General Stores, Inc.
One SE Convenience Blvd
Ankeny IA 50021
Re:Casey’s General Stores, Inc.
Form 10-K for Fiscal Year Ended April 30, 2022
Filed June 24, 2022
File No. 001-34700
Dear Stephen Bramlage:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended April 30, 2022
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 25
1.It is not clear how your disclosure fully explains the change in operating cash flow from
period to period for all periods presented. Your current disclosure appears to indicate how
operating cash flow for the latest year presented was determined. Additionally, your
disclosure references income tax receivable, inventories, and accrued expenses. Note that
references to these items may not provide a sufficient basis to understand how operating
cash actually was affected between periods. Your discussion should be a comparable
analysis between periods that discusses all material factors that actually affected operating
cash. Also, your analysis should discuss the reasons underlying factors cited, particularly
in regard to changes for which the impact on cash is not readily apparent. Refer to Item
303(b) of Regulation S-K, the introductory paragraph of section IV.B and paragraph B.1
of Release No. 33-8350 for guidance, and section 501.04 of our Codification of Financial
FirstName LastNameStephen Bramlage, Jr.
Comapany NameCasey’s General Stores, Inc.
February 10, 2023 Page 2
FirstName LastName
Stephen Bramlage, Jr.
Casey’s General Stores, Inc.
February 10, 2023
Page 2
Reporting Releases regarding quantification of variance factors cited. Please revise your
disclosure as appropriate.
Consolidated Statements of Income, page 35
2.Please explain to us and in your filing what footnote (a) at the end of the line item "Cost
of goods sold ..." refers to.
Note 1. Significant Accounting Policies
Inventories, page 38
3.Please describe what "renewable identification numbers" represent and how you obtain
and use or sell them.
Notes to Consolidated Financial Statements
Note 7. Leases, page 51
4.Please explain to us where the disclosure for cash paid for amounts included in the
measurement of lease liabilities pursuant to ASC 842-20-50-4.g.1 is located.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Patrick Kuhn at (202) 551-3308 or Doug Jones at (202) 551-3309 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services