SEC Comment Letter 0000000000-24-002104 to CASEYS GENERAL STORES INC (CASY) (CIK 0000726958) (CASY)
CASEYS GENERAL STORES INC (CASY) (CIK 0000726958)
Date: Feb. 26, 2024 · CIK: 0000726958 · Accession: 0000000000-24-002104
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File numbers found in text: 001-34700
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United States securities and exchange commission logo
February 26, 2024
Stephen Bramlage, Jr.
Chief Financial Officer
Casey’s General Stores, Inc.
One SE Convenience Blvd.
Ankeny, Iowa 50021
Re:Casey’s General Stores, Inc.
Form 10-K for Fiscal Year Ended April 30, 2023
File No. 001-34700
Dear Stephen Bramlage:
We have reviewed your filing and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended April 30, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Fiscal 2023 Compared with Fiscal 2022, page 21
1.Where you identify multiple factors which contributed to material changes in your period
over period results, please expand your disclosures to quantify the individual impact of
each factor. As an example, your non-fuel revenues were impacted by operating
more stores than a year ago, strategic retail price adjustments, and strong or increased
sales without providing quantification of the individual factors cited to allow users to
understand the magnitude and relative impact of each factor. Additionally, to the extent
you can quantify the impact inflation has had on your pricing and cost of good sold, please
revise to provide such quantification. Refer to Item 303 of Regulation S-K and section
III.D of Release No. 33-6835.
Liquidity and Capital Resources, page 25
2.In your analysis of changes in reported operating cash flows you refer to the impact of
deferred taxes. It appears deferred taxes are a noncash item that do not directly impact
cash of operating activities. You also refer to the change in income tax balances as a factor
FirstName LastNameStephen Bramlage, Jr.
Comapany NameCasey’s General Stores, Inc.
February 26, 2024 Page 2
FirstName LastName
Stephen Bramlage, Jr.
Casey’s General Stores, Inc.
February 26, 2024
Page 2
for the increase in operating activities in 2023 compared to 2022. However, the
supplemental disclosures of cash flows information reports cash paid for income taxes
was a greater direct use of operating cash in 2023 compared to 2022 in contradiction to
what the change in income tax balances indicates. Substituting this direct use of cash for
income taxes paid for the indirect change in income tax balances appears to impact the
overall analysis of material factors contributing to changes in operating activities between
periods. Please note reference to reconciling items presented in the statement of cash
flows in deriving reported operating cash flows for a period may not necessarily provide a
sufficient basis to understand how actual operating cash was directly affected between
periods. Refer to the introductory paragraph of section IV.B and B.1 of Release No. 33-
8350 for guidance on the analysis of operating cash flows and incorporate it in your
analysis as appropriate.
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.
Please contact Abe Friedman at 202-551-8298 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services