SEC Comment Letter for MANATRON INC (CIK 0000798736) — Dec 23, 2005
MANATRON INC (CIK 0000798736)
Date: Dec. 23, 2005 · CIK: 0000798736 · Accession: 0000000000-05-063843
AI Filing Summary & Sentiment
File numbers found in text: 000-15264
Referenced dates: October 28, 2005
Letter
December 23, 2005 Room 4561 Paul R. Sylvester President, Chief Executive Officer and Director Manatron, Inc. 510 East Milham Avenue Portage, Michigan 49002
Re: Manatron, Inc. Form 10-K for Fiscal Year Ended April 30, 2005 Form 10-Q for Fiscal Quarter Ended July 31, 2005 File No. 000-15264
Dear Mr. Sylvester:
We have reviewed your response to our letter dated October 28, 2005 in connection with our review of the above referenced filings and have the following comments. Please note that we have limited our review to the matters addressed in the comments below. We may ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. After reviewing this information, we may 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Balance Sheet, page A-3
We note your response to prior comment 2 and that you believe percentage of completion is appropriate for your appraisal services. Explain to us why you believe it is appropriate to recognize revenue in this manner. Please note that footnote 1 of SOP 81-1 does not permit the use of contract accounting for service contracts.
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. You may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter with any amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing any amendment and your responses to our comments.
You may contact Melissa Rocha at (202) 551-3854 or Marc Thomas, Senior Accountant at (202) 551-3452 or me at (202) 551-3730 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Brad Skinner
Accounting Branch Chief
Show Raw Text
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<TEXT>
December 23, 2005
Room 4561
Paul R. Sylvester
President, Chief Executive Officer and Director
Manatron, Inc.
510 East Milham Avenue
Portage, Michigan 49002
Re: Manatron, Inc.
Form 10-K for Fiscal Year Ended April 30, 2005
Form 10-Q for Fiscal Quarter Ended July 31, 2005
File No. 000-15264
Dear Mr. Sylvester:
We have reviewed your response to our letter dated October
28,
2005 in connection with our review of the above referenced filings
and have the following comments. Please note that we have limited
our review to the matters addressed in the comments below. We may
ask you to provide us with supplemental information so we may
better
understand your disclosure. Please be as detailed as necessary in
your explanation. After reviewing this information, we may 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Balance Sheet, page A-3
We note your response to prior comment 2 and that you believe
percentage of completion is appropriate for your appraisal
services.
Explain to us why you believe it is appropriate to recognize
revenue
in this manner. Please note that footnote 1 of SOP 81-1 does not
permit the use of contract accounting for service contracts.
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T. You
may wish to provide us with marked copies of any amendment to
expedite our review. Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information. Detailed cover letters greatly facilitate
our
review. Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.
You may contact Melissa Rocha at (202) 551-3854 or Marc
Thomas,
Senior Accountant at (202) 551-3452 or me at (202) 551-3730 if you
have questions regarding comments on the financial statements and
related matters.
Sincerely,
Brad Skinner
Accounting Branch Chief
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Paul R. Sylvester
Manatron, Inc.
December 23, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
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