SEC Comment Letter for DELTA WOODSIDE INDUSTRIES — Mar 7, 2005
DELTA WOODSIDE INDUSTRIES INC /SC/ (CIK 0000806624)
Date: March 7, 2005 · CIK: 0000806624 · Accession: 0000000000-05-010744
AI Filing Summary & Sentiment
Letter
March 8, 2005 By Facsimile and U.S. Mail Mr. William F. Garrett President, Chief Executive Officer and Director Delta Woodside Industries, Inc. P.O. Box 6126 100 Augusta Street Greenville, SC 29606
Re: Form 10-K for the year ended July 3, 2004 Form 10-Q for the period ended October 2, 2004 File No. 1-10095
Dear Mr. Garrett:
We have reviewed your February 28th response letter and have the following additional comment. Form 10-K for the year ended July 3, 2004
Note G - Commitments and Contingencies
1. We note your response to prior comment 11. Please tell us how you account for the IDR bonds in the sale leaseback exchange, the bond amounts and the amounts of any items they offset. Also advise us of your basis for presuming that a legal right to offset exists. Include references to applicable accounting pronouncements to support your conclusions. Then, tell us how you accounted for the sale and leaseback for each of the properties specifically as it relates to whether you have consummated each sale, the buyer`s initial and continuing investments, your continuing involvement in the properties and the method for your recognition of profits, if applicable. Refer to SFAS`s No. 66 and 98.
Please send us your response to our comment within 10 business days from the date of this letter or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your response to our comment. Your supplemental response letter should be submitted in electronic form on EDGAR as a correspondence file. Refer to Rule 101(a) of Regulation S-T.
If you have any questions regarding our comments, please direct them to Brian V. McAllister at (202) 824-5664 or, Donna Di Silvio at (202) 942-1852, or in her absence to the undersigned at (202) 942-2823.
Sincerely,
Mike Moran
Accounting Branch
Chief
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Mail Stop 3-8
March 8, 2005
By Facsimile and U.S. Mail
Mr. William F. Garrett
President, Chief Executive Officer and Director
Delta Woodside Industries, Inc.
P.O. Box 6126
100 Augusta Street
Greenville, SC 29606
Re: Form 10-K for the year ended July 3, 2004
Form 10-Q for the period ended October 2, 2004
File No. 1-10095
Dear Mr. Garrett:
We have reviewed your February 28th response letter and
have the following additional comment.
Form 10-K for the year ended July 3, 2004
Note G - Commitments and Contingencies
1. We note your response to prior comment 11. Please tell us how
you
account for the IDR bonds in the sale leaseback exchange, the bond
amounts and the amounts of any items they offset. Also advise us
of
your basis for presuming that a legal right to offset exists.
Include references to applicable accounting pronouncements to
support
your conclusions. Then, tell us how you accounted for the sale
and
leaseback for each of the properties specifically as it relates to
whether you have consummated each sale, the buyer`s initial and
continuing investments, your continuing involvement in the
properties
and the method for your recognition of profits, if applicable.
Refer
to SFAS`s No. 66 and 98.
Please send us your response to our comment within 10
business
days from the date of this letter or tell us when you will provide
us
with a response. Please understand that we may have additional
comments after reviewing your response to our comment. Your
supplemental response letter should be submitted in electronic
form
on EDGAR as a correspondence file. Refer to Rule 101(a) of
Regulation S-T.
If you have any questions regarding our comments, please
direct them to Brian V. McAllister at (202) 824-5664 or, Donna Di
Silvio at (202) 942-1852, or in her absence to the undersigned at
(202) 942-2823.
Sincerely,
Mike Moran
Accounting Branch
Chief
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??
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Mr. William F. Garrett
Delta Woodside Industries, Inc.
March 8, 2005
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