SEC Comment Letter for ATMOS ENERGY CORP (ATO) (CIK 0000731802) (ATO) — Jun 15, 2010
ATMOS ENERGY CORP (ATO) (CIK 0000731802)
Date: June 15, 2010 · CIK: 0000731802 · Accession: 0000000000-10-033470
AI Filing Summary & Sentiment
File numbers found in text: 001-10042
Referenced dates: June 1, 2010, June 1, 2010
Letter
June 15, 2010
Fred E. Meisenheimer Senior Vice President and Chief Financial Officer Atmos Energy Corporation Three Lincoln Centre, Suite 1800 5430 LBJ Freeway Dallas, Texas 75240 Re: Atmos Energy Corporation Form 10-K for Fiscal Ye ar Ended September 30, 2009 Filed November 16, 2009 File No. 001-10042 Dear Mr. Meisenheimer: We have reviewed your response dated June 9, 2010 to our comment letter dated June 1, 2010 and have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Item 7. Management’s Discussion and Analys is of Financial Condition and Results of Operations, page 35
Results of Operations, page 40
Consolidated Results, page 41 1. We reviewed your response to comment one in our letter dated June 1, 2010. Please tell us in detail how your previous method of estim ating the tax rate at which deferred taxes are projected to reverse in future periods complied with GAAP, and specifically the guidance in ASC 740-10-30-5. Further, please refer to ASC 250-10 and tell us your consideration as to whether th e revision to the tax rates used to record deferred taxes represents the correction of an error that existed in the pr ior period financial statements as opposed to a change in accounting estimate. In this regard, we note that by definition, changes in accounting estimates result from the evaluation of new information and not a
Fred E. Meisenheimer Atmos Energy Corporation June 15, 2010 Page 2
revised evaluation of information that existed at the previous balance sheet dates. Refer to the glossary at ASC 250-10-20. Please tell us what new information was available in the second quarter of fiscal year 2009 that was not available at the previous balance sheet dates.
You may contact Robyn Manuel at 202-551-3823 if you have questions regarding the comment on the financial statements and rela ted matters. Please contact me at 202-551-3344 with any other questions. Sincerely,
William Thompson Branch Chief
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June 15, 2010 Fred E. Meisenheimer Senior Vice President and Chief Financial Officer Atmos Energy Corporation Three Lincoln Centre, Suite 1800 5430 LBJ Freeway Dallas, Texas 75240 Re: Atmos Energy Corporation Form 10-K for Fiscal Ye ar Ended September 30, 2009 Filed November 16, 2009 File No. 001-10042 Dear Mr. Meisenheimer: We have reviewed your response dated June 9, 2010 to our comment letter dated June 1, 2010 and have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Item 7. Management’s Discussion and Analys is of Financial Condition and Results of Operations, page 35 Results of Operations, page 40 Consolidated Results, page 41 1. We reviewed your response to comment one in our letter dated June 1, 2010. Please tell us in detail how your previous method of estim ating the tax rate at which deferred taxes are projected to reverse in future periods complied with GAAP, and specifically the guidance in ASC 740-10-30-5. Further, please refer to ASC 250-10 and tell us your consideration as to whether th e revision to the tax rates used to record deferred taxes represents the correction of an error that existed in the pr ior period financial statements as opposed to a change in accounting estimate. In this regard, we note that by definition, changes in accounting estimates result from the evaluation of new information and not a Fred E. Meisenheimer Atmos Energy Corporation June 15, 2010 Page 2 revised evaluation of information that existed at the previous balance sheet dates. Refer to the glossary at ASC 250-10-20. Please tell us what new information was available in the second quarter of fiscal year 2009 that was not available at the previous balance sheet dates. You may contact Robyn Manuel at 202-551-3823 if you have questions regarding the comment on the financial statements and rela ted matters. Please contact me at 202-551-3344 with any other questions. Sincerely, William Thompson Branch Chief