SEC Comment Letter for DLH Holdings Corp. (DLHC) (CIK 0000785557) (DLHC) — Aug 24, 2006
DLH Holdings Corp. (DLHC) (CIK 0000785557)
Date: Aug. 24, 2006 · CIK: 0000785557 · Accession: 0000000000-06-041092
AI Filing Summary & Sentiment
Reasoning
Referenced dates: August 8, 2006, July 11, 2006
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 August 24, 2006 Via U.S. Mail Mr. Rick J. Filippelli Vice President, Finance, Chief Financial Officer 300 Atrium Drive Somerset NJ 08873 Forms 10-Q for Fiscal Quarters Ended December 31, 2005, March 31, 2006, and June 30, 2006 File No. 0-18492
RE: TeamStaff, Inc Form 10-K for Fiscal Year Ended September 30, 2005 Filed December 21, 2005
Dear Mr. Filippelli:
We have reviewed your supplemental response letter dated August 8, 2006 as well as your filing and have the following comments. As noted in our comment letter dated July 11, 2006, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
1. We note your response to prior comment 6 with respect to your RS Staffing acquisition. We note that you decided not to break out the trade name separately and included it instead in the calculation of goodwill, since the trade name is not amortizable. Your accounting does not appear to comply with paragraphs 37 and 39 of SFAS 141. Please note that the accounting for and impairment testing for an intangible asset not subject to amortization, such as your trade name, is different from the accounting for goodwill. Refer to paragraphs 16-17 of SFAS 142. Please revise.
2. Refer to your response to our prior comment number 7. In future filings, enhance your MD&A discussion of the realizability of deferred tax assets by including a description of the factors used to reach such a conclusion similar to that provided in your response.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. You may contact Nicole Holden Staff Accountant, at
Mr. Rick J. Filippelli Teamstaff, Inc August 24, 2006 Page 2 (202) 551-3374 or Kyle Moffatt, Accountant Branch Chief, at (202) 551-3836 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions.
S i n c e r e l y ,
L a r r y S p i r g e l A s s i s t a n t D i r e c t o r
cc: James Huston, counsel Cheryl Presuto, Controller
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
August 24, 2006
Via U.S. Mail
Mr. Rick J. Filippelli
Vice President, Finance, Chief Financial Officer
300 Atrium Drive
Somerset NJ 08873
RE: TeamStaff, Inc
Form 10-K for Fiscal Year Ended September 30, 2005
Filed December 21, 2005
Forms 10-Q for Fiscal Quarters Ended December 31, 2005, March 31,
2006, and June 30, 2006
File No. 0-18492
Dear Mr. Filippelli:
We have reviewed your supplemental response letter dated August 8, 2006 as
well as your filing and have the following comments. As noted in our comment letter
dated July 11, 2006, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
1. We note your response to prior comment 6 with respect to your RS Staffing acquisition. We note that you decided not to break out the trade name separately and included it instead in the calculation of goodwill, since the trade name is not amortizable. Your accounting does not appear to comply with paragraphs 37 and 39 of SFAS 141. Please note that the accounting for and impairment testing for an intangible asset not subject to amortization, such as your trade name, is different from the accounting for goodwill. Refer to paragraphs 16-17 of SFAS 142. Please revise.
2. Refer to your response to our prior comment number 7. In future filings, enhance your MD&A discussion of the realizability of deferred tax assets by including a description of the factors used to reach such a conclusion similar to that provided in your response.
* * * *
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. You may contact Nicole Holden Staff Accountant, at
Mr. Rick J. Filippelli
Teamstaff, Inc
August 24, 2006 Page 2
(202) 551-3374 or Kyle Moffatt, Accountant Branch Chief, at (202) 551-3836 if you
have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions.
S i n c e r e l y ,
L a r r y S p i r g e l
A s s i s t a n t D i r e c t o r
cc: James Huston, counsel
Cheryl Presuto, Controller