SEC Comment Letter for ATMOS ENERGY CORP (ATO) (CIK 0000731802) (ATO) — May 2, 2017
ATMOS ENERGY CORP (ATO) (CIK 0000731802)
Date: May 2, 2017 · CIK: 0000731802 · Accession: 0000000000-17-015326
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 May 2, 2017 Bret J. Eckert 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 the Fiscal Year Ended September 30 , 2016 Filed Nov ember 14, 2016 File No. 1-10042
Dear Mr. Eckert :
We have reviewed your filing an d have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circums tances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Consolidated Statements of Income, page 47
1. Please tell us your basis for presenting gross profit. In this regard, we note you exclude depreciation and amortization and operating and maintenance costs from gross profit. To avoid placing undue emphasis on cash flow, depreciation and amortization sh ould not be positioned in the income statement in a manner which results in reporting a figure for income before depreciation. Refer to ASC 225 -10-S99-8.
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 Tony Watson, Accountant, at (202) 551 -3318 if you have questions regarding comments on the financial statements and related matters. Pleas e contact Scott
Bret J. Eckert Atmos Energy Corporation May 2, 2017 Page 2
Anderegg (Staff Attorney) at (202) 551 -3342 or Mara Ransom ( Assistant Director) at (202) 551 - 3264 or me at (202) 551 -3344 with any other questions .
Sincerely,
/s/ William H. Thompson
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Mail Stop 3561 May 2, 2017 Bret J. Eckert 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 the Fiscal Year Ended September 30 , 2016 Filed Nov ember 14, 2016 File No. 1-10042 Dear Mr. Eckert : We have reviewed your filing an d have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circums tances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Consolidated Statements of Income, page 47 1. Please tell us your basis for presenting gross profit. In this regard, we note you exclude depreciation and amortization and operating and maintenance costs from gross profit. To avoid placing undue emphasis on cash flow, depreciation and amortization sh ould not be positioned in the income statement in a manner which results in reporting a figure for income before depreciation. Refer to ASC 225 -10-S99-8. 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 Tony Watson, Accountant, at (202) 551 -3318 if you have questions regarding comments on the financial statements and related matters. Pleas e contact Scott Bret J. Eckert Atmos Energy Corporation May 2, 2017 Page 2 Anderegg (Staff Attorney) at (202) 551 -3342 or Mara Ransom ( Assistant Director) at (202) 551 - 3264 or me at (202) 551 -3344 with any other questions . Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief Office of Consumer Products