SEC Comment Letter for DELTA WOODSIDE INDUSTRIES — Mar 25, 2005
DELTA WOODSIDE INDUSTRIES INC /SC/ (CIK 0000806624)
Date: March 25, 2005 · CIK: 0000806624 · Accession: 0000000000-05-013960
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<TYPE>LETTER
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<FILENAME>filename1.txt
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Mail Stop 3-8
March 25, 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 March 22nd 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 our prior comment. Please disclose
how
the fee-in-lieu-of-tax transaction is reflected in your
consolidated
financial statements as a deferred financing lease. If the
transaction is not reflected in the financial statements, disclose
why and include any applicable accounting pronouncement(s) to
support
your conclusion. Specifically indicate in your disclosure whether
there are any cash inflows and outflows between you and any entity
as
it relates to the IDR Bond and the lease transactions. If no cash
is
exchanged disclose why. If cash is exchanged, please tell us and
disclose:
* The amounts, timing and nature of such cash flows (e.g. bond
payment, lease payment, interest expense and/or income and fee-in-
lieu-of-taxes);
* Where these amounts are reflected in your statements of
financial
position, earnings and cash flows; and
* The amounts of payments for the 2004, 2003 and 2002 fee-in-lieu-
of-
taxes in comparison to forgone property taxes.
Also, please disclose the following:
* The terms and uncertainties of the IDR Bond and property leases;
* Your basis for the right to offset the IDR Bond with the
associated
lease obligations as well as the related receipts and payments;
* The adjusting estimated real property tax payments if it is at
least reasonably possible that you may reacquire the properties
either at your election or due to external risks or uncertainties;
* Or, specifically state that you can not estimate the required
adjusting estimated real property taxes payments.
Please provide us with an example of the disclosure in your
response
or an explanation why you believe this disclosure is not
applicable
to you.
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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Mr. William F. Garrett
Delta Woodside Industries, Inc.
March 8, 2005
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