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SEC Company Response from ATMOS ENERGY CORP (ATO) (CIK 0000731802) (ATO) — May 4, 2017

ATMOS ENERGY CORP (ATO) (CIK 0000731802)
Date: May 4, 2017 · CIK: 0000731802 · Accession: 0000731802-17-000020

AI Filing Summary & Sentiment

Referenced dates: May 2, 2017

Date
May 4, 2017
Author
/s/ CHRISTOPHER T. FORSYTHE
Form
CORRESP
Company
ATMOS ENERGY CORP (ATO) (CIK 0000731802)

Letter

Division of Corporation Finance Re: Atmos Energy Corporation Form 10-K for the Fiscal Year ended September 30, 2016, Filed November 14, 2016 File No. 1-10042

Dear Mr. Thompson:

We are responding to your letter dated May 2, 2017, commenting on our most recent Form 10-K filed with the Commission. We have repeated your comment from such letter below, followed by our response to the comment in bold print. We intend to comply with the comment in all future filings, as applicable.

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 should 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 reviewed the guidance in ASC 225-10-S99-8 and as a result, we will remove the subtotal “Gross profit” appearing in the income statements in our Financial Information and Supplementary Data in all our future Form 10-K and Form 10-Q filings, beginning with our Form 10-Q for the three and six months ended March 31, 2017.

Mr. William H. Thompson

U.S. Securities and Exchange Commission

May 4, 2017

Page 2

If you have any questions or comments on this letter, please direct them to our Controller, Richard M. Thomas at (972) 855-3748, or in his absence, to me at (972) 855-3214. Thank you for your attention.

Sincerely,
/s/ CHRISTOPHER T. FORSYTHE

Show Raw Text
CORRESP
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filename1.htm

		Document

Mr. William H. Thompson

U.S. Securities and Exchange Commission

May 4, 2017

Page 1

May 4, 2017

By: EDGAR Transmission - Correspondence Filing

Mr. William H. Thompson

Accounting Branch Chief

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Re:    Atmos Energy Corporation

Form 10-K for the Fiscal Year ended September 30, 2016,

Filed November 14, 2016

File No. 1-10042

Dear Mr. Thompson:

We are responding to your letter dated May 2, 2017, commenting on our most recent Form 10-K filed with the Commission.  We have repeated your comment from such letter below, followed by our response to the comment in bold print.  We intend to comply with the comment in all future filings, as applicable.

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 should 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 reviewed the guidance in ASC 225-10-S99-8 and as a result, we will remove the subtotal “Gross profit” appearing in the income statements in our Financial Information and Supplementary Data in all our future Form 10-K and Form 10-Q filings, beginning with our Form 10-Q for the three and six months ended March 31, 2017.

Mr. William H. Thompson

U.S. Securities and Exchange Commission

May 4, 2017

Page 2

If you have any questions or comments on this letter, please direct them to our Controller, Richard M. Thomas at (972) 855-3748, or in his absence, to me at (972) 855-3214.  Thank you for your attention.

Sincerely,

/s/ CHRISTOPHER T. FORSYTHE

Christopher T. Forsythe

Senior Vice President and

Chief Financial Officer

cc:  Mr. Anthony W. Watson

       U.S. Securities and Exchange Commission

       Mr. Scott Anderegg

       U.S. Securities and Exchange Commission

       Ms. Mara Ransom

       U.S. Securities and Exchange Commission