SEC Comment Letter for ICAHN ENTERPRISES L.P. (IEP) (CIK 0000813762) (IEP) — Jul 28, 2011
ICAHN ENTERPRISES L.P. (IEP) (CIK 0000813762)
Date: July 28, 2011 · CIK: 0000813762 · Accession: 0000000000-11-045650
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-09516
Referenced dates: July 5, 2011
Letter
Re: Icahn Enterprises L.P. Form 10-K for the fiscal year ended December 31, 2010 Filed March 8, 2011 File No. 001-09516 Dear Mr. Ragone: We have reviewed your response letter dated July 5, 2011 and have the following comment. Unless otherwise indicated, we thin k you should revise your document in future filings in response to these comments. If you disa gree, we will consider y our explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Af ter 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 requir ements 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 fr ee to call us at the telephone numbers listed at the end of th is letter.
July 28, 2011 Via Email
Mr. Dominick Ragone Chief Financial Officer Icahn Enterprises L.P. 767 Fifth Avenue, Suite 4700 New York, New York 10153
Please respond to confirm that such comments will be complied with, or, if certain of the comments are deemed inappropriate, advise the staff of your reason. Your response should be submitted in electronic form, under the label “corres p” with a copy to the staff. Please respond within ten (10) business days. Form 10-K for the Year Ended December 31, 2010
1. We note your response to our prior comment nu mber one however we reissue in part. Your response did not address the reason for the difference in the two fair values which according to your response in your letter date d June 7, 2011 were both calculated as of November 15, 2010. Please also explain w hy you believe the fair value of $19.50 per share as determined, with the assistance of the third-party appraiser, rather than the price
Mr. Dominick Ragone Icahn Enterprises L.P. July 28, 2011 Page 2
of Tropicana’s common stock traded in the privately negotiated transaction at $13.75 per share is appropriate for ca lculating the gain or loss in the transaction.
You may contact Claire Erla nger at (202)551-3301 or Jean Yu at (202)551-3305 if you have questions regarding comments on the fina ncial statements and related matters.
Sincerely,
/s/ Linda Cvrkel
Linda Cvrkel Branch Chief
Show Raw Text
July 28, 2011 Via Email Mr. Dominick Ragone Chief Financial Officer Icahn Enterprises L.P. 767 Fifth Avenue, Suite 4700 New York, New York 10153 Re: Icahn Enterprises L.P. Form 10-K for the fiscal year ended December 31, 2010 Filed March 8, 2011 File No. 001-09516 Dear Mr. Ragone: We have reviewed your response letter dated July 5, 2011 and have the following comment. Unless otherwise indicated, we thin k you should revise your document in future filings in response to these comments. If you disa gree, we will consider y our explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Af ter 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 requir ements 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 fr ee to call us at the telephone numbers listed at the end of th is letter. Please respond to confirm that such comments will be complied with, or, if certain of the comments are deemed inappropriate, advise the staff of your reason. Your response should be submitted in electronic form, under the label “corres p” with a copy to the staff. Please respond within ten (10) business days. Form 10-K for the Year Ended December 31, 2010 1. We note your response to our prior comment nu mber one however we reissue in part. Your response did not address the reason for the difference in the two fair values which according to your response in your letter date d June 7, 2011 were both calculated as of November 15, 2010. Please also explain w hy you believe the fair value of $19.50 per share as determined, with the assistance of the third-party appraiser, rather than the price Mr. Dominick Ragone Icahn Enterprises L.P. July 28, 2011 Page 2 of Tropicana’s common stock traded in the privately negotiated transaction at $13.75 per share is appropriate for ca lculating the gain or loss in the transaction. You may contact Claire Erla nger at (202)551-3301 or Jean Yu at (202)551-3305 if you have questions regarding comments on the fina ncial statements and related matters. Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief