SEC Company Response from GARB OIL & POWER CORP (CIK 0000798371) — Mar 30, 2005
GARB OIL & POWER CORP (CIK 0000798371)
Date: March 30, 2005 · CIK: 0000798371 · Accession: 0001038838-05-000371
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GARB OIL AND POWER CORPORATION
SUPPLEMENTAL INFORMATION
JUNE 30, 2004
RESPONSE TO INQUIRIES BY SECURITIES AND EXCHANGE COMMISSION
MANAGEMENT'S DISCUSSION AND ANALYSIS OR PLAN OF OPERATION - Page 14
1. The Company is no longer considered to be in a development stage. The
Company exited the development stage on June 30, 2004 and will be
reported as such in the future.
2. Some terminology used in referencing changes in working capital with
respect to "unearned revenue", is confusing. Deferred income, Customer
deposits and Unearned revenue all refer to the same item - customer
pre-payments on sales contracts. There will be more consistent use of
account names in future reporting.
3. There will be more detailed discussion of revenues and expenses and
results of operations as required by Item 303 of Regulation S-B in
future reports.
4. Regarding UTTI, for more than two years the tire repair equipment has
been stored in facilities in Illinois for use by a company associated
with Garb-Oil. Consequently there has been no storage or rental expense
related to the UTTI tire repair equipment during this time. Current
plans include use of this machinery at facilities owned by a purchaser
of one of the company's shredders.
A current report for this item is also planned for the fiscal 10K
filing of the Company.
5. As discussed in item 14, the Company has sold to more than one
customer.
6. Most of the liabilities are owed to the President John C. Brewer and
the balance of Corporate debt is owed to friendly sources who have made
no demands for payment.
Current funding has come from operations and sales and the Company is
currently in negotiations with sources for investment in the company
that would satisfy long term operations and capital expenditures, if
successful.
At the end of this fiscal year (June 30, 2005 Form 10K filing), the
Company will explain and report results of its efforts in current
funding negotiations and its plans for operations.
Financial Statements
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Report of Independent Registered Public Accounting Firm
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7. The audit report will properly reference the Public Company Accounting
Oversight Board.
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Balance Sheet - Page F-4
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8. Assets held for resale were designated as such during the development
stage of the Company. Having exited the development stage, the Company
has begun using some of these assets in the construction of machines
for sale and has sold some of these assets outright, subsequent to June
30, 2004.
9. Assets under construction shown as Other Assets, reflects costs being
accumulated for the construction of a shredder machine to be sold.
These costs were shown as Other Assets because the time of completion
and delivery of this machine was uncertain at the time.
Note 1 - Organization and Summary of Significant Accounting Policies
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(c) Basis of Presentation - Going Concern - Page F-9
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10. The company sells tire shredders and has sold three machines in the
last year. The Company also imports new tires from China to be sold
through Black Minority Distributors. The company has imported two
orders of new tires for a total of $290,000.00. A new scrap tire
processing machine owned by the company is being developed in China and
the pilot model is expected to be completed before the end of 2005.
Additional information regarding this new machine and future plans for
sales and operations will be more thoroughly reported and explained in
our June 30, 2005 fiscal year form 10K.
(g) Revenue Recognition - Page F-10
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11. Disclosure policy regarding the manufacture and sale of tire shredder
machines will be discussed in greater detail in future filings.
12. The Company shows as Deferred income or Customer deposits, prepayments
on contracts to deliver tires or shredder machines to customers at a
later date. These deposits are recognized as income to the Company upon
delivery of the product and completion of the contract.
13. Customers are required to deposit with, or pre-pay to, the Company
certain contractually specified amounts at the inception of a sales
contract. These amounts are held by the company as unearned revenue
until the completion of the contract, usually delivery of the product,
at which time the income and associated costs of the contract project
are recognized by the Company.
(l) Concentration of Credit Risk - Page F-11
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14. Paragraph (g) refers to "single customers"; in clarification, this
means one large contract sale to a single customer, i.e., there have
been several customers to which the Company has sold product during
2003 and 2004.
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Note 5 Commitments - Page F-14
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15. The company in the Ukraine (Micron) referenced in this note, was unable
to perform and the contract was cancelled. This will be more thoroughly
reported in our June 30, 2005 form 10K filing.
The machine is now currently under development in China as explained in
item #10 above. As reported in Note 1(c) above, the pilot model is
expected to be completed before the end of 2005.
Forms 10-QSB for 9/30/04 and 12/31/04
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16. In future filings, the Company will separately state the different
types of revenues, i.e., tire sales, machine sales, etc.
17. In future filings, the Company will provide in its Management's
Discussion and Analysis, detailed discussion of Results of Operations,
including details of revenues, cost of sales, gross margin and
expenses, included in the financial statements.
18. The Company issued Treasury Stock in satisfaction of a note payable
with accrued interest. This will be discussed in more detail and
disclosed in the footnotes in future filings.
SIGNATURES
In accordance with Section 13 or 15(d) of the Securities Exchange Act,
the Registrant caused this report to be signed on its behalf by the undersigned,
thereunto duly authorized.
GARB OIL & POWER CORPORATION
By: /s/ John C. Brewer
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John C. Brewer, Chief Executive Officer
DATED this 16th Day of March, 2005
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