SEC Comment Letter for ICAHN ENTERPRISES L.P. (IEP) (CIK 0000813762) (IEP) — Jun 23, 2009
ICAHN ENTERPRISES L.P. (IEP) (CIK 0000813762)
Date: June 23, 2009 · CIK: 0000813762 · Accession: 0000000000-09-033038
AI Filing Summary & Sentiment
Reasoning
Referenced dates: May 13, 2009
Letter
Mail Stop 3010 June 23, 2009 Via U.S. Mail and Facsimile 917.591.3412 Mr. Dominick Ragone Chief Financial Officer of Icahn Enterprise s G.P. Inc., the General Partner of Icahn Enterprises L.P. Icahn Enterprises L.P. 767 Fifth Street, Suite 4700 New York, NY 10153
Re: Icahn Enterprises L.P. Form 10-K for fiscal ye ar ended December 31, 2008 Filed March 4, 2009 File No. 1-9516
Dear Mr. Ragone:
We have reviewed your response letter dated May 13, 2009 and have the following additional comment. If you disagree with our comment, we will consider your explanation as to why our comment is not applic able. 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 re view 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 comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Dominick Ragone Icahn Enterprises, L.P. June 23, 2009 Page 2 Form 10-K for the fiscal year ended December 31, 2008
Item 8. Financial Statements and Supplementary Data
1. We note your response to prior comments five , seven, and eight. We continue to believe that your disclosures are not in accordance with Rule 5-02 and Rule 5-03 of Regulation S-X. Please amend your Fo rm 10-K as of and for the fiscal year ended December 31, 2008 to comply with Re gulation S-X. You may continue to present your financial statements base d on significant segments, however the financial statements requested above in accordance with Rule 5-02 and 5-03 must precede your financial statements prepared on a segmented basis.
* * * *
As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please submit a response letter on EDGAR that keys your response to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please understa nd that we may have additional comments after reviewin g your response to our comment.
You may contact Mark Rakip, Sta ff Accountant, at 202.551.3573 or the undersigned at 202.551.3629 if you have questions.
S i n c e r e l y , Kevin Woody Accounting Branch Chief
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Mail Stop 3010
June 23, 2009
Via U.S. Mail and Facsimile 917.591.3412
Mr. Dominick Ragone Chief Financial Officer of Icahn Enterprise s G.P. Inc., the General Partner of Icahn
Enterprises L.P.
Icahn Enterprises L.P. 767 Fifth Street, Suite 4700 New York, NY 10153
Re: Icahn Enterprises L.P.
Form 10-K for fiscal ye ar ended December 31, 2008
Filed March 4, 2009
File No. 1-9516
Dear Mr. Ragone:
We have reviewed your response letter dated May 13, 2009 and have the
following additional comment. If you disagree with our comment, we will consider your explanation as to why our comment is not applic able. 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 re view 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 comment or on any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
Dominick Ragone
Icahn Enterprises, L.P. June 23, 2009 Page 2 Form 10-K for the fiscal year ended December 31, 2008
Item 8. Financial Statements and Supplementary Data
1. We note your response to prior comments five , seven, and eight. We continue to
believe that your disclosures are not in accordance with Rule 5-02 and Rule 5-03
of Regulation S-X. Please amend your Fo rm 10-K as of and for the fiscal year
ended December 31, 2008 to comply with Re gulation S-X. You may continue to
present your financial statements base d on significant segments, however the
financial statements requested above in accordance with Rule 5-02 and 5-03 must
precede your financial statements prepared on a segmented basis.
* * * *
As appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response. Please submit a response letter on EDGAR that keys your response to our comment and provides any requested information.
Detailed cover letters greatly facilitate our review. Please understa nd that we may have
additional comments after reviewin g your response to our comment.
You may contact Mark Rakip, Sta ff Accountant, at 202.551.3573 or the
undersigned at 202.551.3629 if you have questions.
S i n c e r e l y ,
Kevin Woody Accounting Branch Chief