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SEC Comment Letter for ARLINGTON HOSPITALITY INC (CIK 0000778423) — Jun 8, 2005

ARLINGTON HOSPITALITY INC (CIK 0000778423)
Date: June 8, 2005 · CIK: 0000778423 · Accession: 0000000000-05-028530

AI Filing Summary & Sentiment

Referenced dates: May 27, 2005

Date
June 8, 2005
Author
Linda Van Doorn
Form
UPLOAD
Company
ARLINGTON HOSPITALITY INC (CIK 0000778423)

Letter

Mail Stop 4561 June 8, 2005 Mr. James B. Dale Chief Financial Officer Arlington Hospitality, Inc. 2355 South Arlington Heights Road, Suite 400 Arlington Heights, Illinois 60005

Re: Arlington Hospitality, Inc. Form10-K for the year ended December 31, 2004 Filed March 31, 2005 File No. 0-15291

Dear Mr. Dale:

We have reviewed your response letter dated May 27, 2005 and have the following additional comments. In our comments, we ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Note 12 Sale of Hotels and Plan for Future Hotel Dispositions, page F-29

1. We note your response to our previous comment number one. If the basis for reporting the proceeds from the sale of these hotels gross is because you are developing and constructing the hotels for sale, explain why you are not reporting hotels under development as a separate line item on your balance sheet. In addition, your impairment policy should be revised to address how you assess and recognize impairment for properties under development. Refer to paragraphs B122 and B123 of SFAS 144. Further, explain why the sales of AmeriHost Inn hotels are not accounted for as discontinued operations under SFAS 144. Refer to the guidelines of EITF 03-13 in your response and also address whether these hotels produce cash flows to you through their operations prior to their sale. If you are operating these hotels prior to

their sale and they are providing operating cash flows, explain why you believe these hotels should be classified as hotels under development and correspondingly why the proceeds from their sales should be reported as revenues rather than net as gain or loss on sale.

2. In your response to our previous comment number two you state "this obligation was contingent since the Company had the option to pay higher rent rather than pay PMC the Assigned Value shortfall, if any, upon the sale of a hotel pursuant to this amendment." Tell us if you paid higher rent during this period.

Note 14 - Commitments, Contingencies and Other Matters, page F-33:

3. We note your response to our previous comments four through six. Please provide us with a schedule showing your accounting for the conversion of the 17 hotels from an operating lease to a capital lease. Specifically, show the amount of the loss recognized in the reduction in fair market value that was considered in the recordation of the capital leases. Please provide the balance sheet activity and statement of operations activity by line item for this transaction and the subsequent activity in these accounts for 2004, including the Arlington Fee and Proceeds Deficit Notes.

Please respond to the comments included in this letter within ten business days. If you have any questions, you may contact Thomas Flinn, Staff Accountant, at (202) 551-3469 or the undersigned at (202) 551-3498 if you have questions.

Sincerely,
Linda Van Doorn
Senior Assistant Chief Accountant

Show Raw Text
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<TEXT>

Mail Stop 4561
      June 8, 2005

Mr. James B. Dale
Chief Financial Officer
Arlington Hospitality, Inc.
2355 South Arlington Heights Road, Suite 400
Arlington Heights, Illinois 60005

	Re:	Arlington Hospitality, Inc.
		Form10-K for the year ended December 31, 2004
		Filed March 31, 2005
		File No. 0-15291

Dear Mr. Dale:

      We have reviewed your response letter dated May 27, 2005 and
have the following additional comments.  In our comments, we ask
you
to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Note 12  Sale of Hotels and Plan for Future Hotel Dispositions,
page
F-29

1. We note your response to our previous comment number one.  If
the
basis for reporting the proceeds from the sale of these hotels
gross
is because you are developing and constructing the hotels for
sale,
explain why you are not reporting hotels under development as a
separate line item on your balance sheet.  In addition, your
impairment policy should be revised to address how you assess and
recognize impairment for properties under development.  Refer to
paragraphs B122 and B123 of SFAS 144.  Further, explain why the
sales
of AmeriHost Inn hotels are not accounted for as discontinued
operations under SFAS 144.   Refer to the guidelines of EITF 03-13
in
your response and also address whether these hotels produce cash
flows to you through their operations prior to their sale.  If you
are operating these hotels prior to

their sale and they are providing operating cash flows, explain
why
you believe these hotels should be classified as hotels under
development and correspondingly why the proceeds from their sales
should be reported as revenues rather than net as gain or loss on
sale.

2. In your response to our previous comment number two you state
"this obligation was contingent since the Company had the option
to
pay higher rent rather than pay PMC the Assigned Value shortfall,
if
any, upon the sale of a hotel pursuant to this amendment." Tell us
if
you paid higher rent during this period.

Note 14 - Commitments, Contingencies and Other Matters, page F-33:

3. We note your response to our previous comments four through
six.
Please provide us with a schedule showing your accounting for the
conversion of the 17 hotels from an operating lease to a capital
lease.  Specifically, show the amount of the loss recognized in
the
reduction in fair market value that was considered in the
recordation
of the capital leases.  Please provide the balance sheet activity
and
statement of operations activity by line item for this transaction
and the subsequent activity in these accounts for 2004, including
the
Arlington Fee and Proceeds Deficit Notes.

      Please respond to the comments included in this letter
within
ten business days.  If you have any questions, you may contact
Thomas
Flinn, Staff Accountant, at (202) 551-3469 or the undersigned at
(202) 551-3498 if you have questions.

      							Sincerely,

      							Linda Van Doorn
Senior Assistant Chief Accountant

Mr. James B. Dale
Arlington Hospitality, Inc.
June 8, 2005
Page 1

</TEXT>
</DOCUMENT>