SEC Comment Letter for HOMEFED CORP (CIK 0000833795) — Apr 21, 2005
HOMEFED CORP (CIK 0000833795)
Date: April 21, 2005 · CIK: 0000833795 · Accession: 0000000000-05-019615
AI Filing Summary & Sentiment
File numbers found in text: 001-10153
Referenced dates: April 8, 2005, April 8, 2005
Letter
Mail Stop 0409 VIA U.S. MAIL AND FAX (760) 918-8210 Ms. Erin Ruhe VP, Treasurer and Controller HomeFed Corporation 1903 Wright Place, Suite 220 Carlsbad, CA 92008
Re: HomeFed Corporation Form 10-K for the year ended December 31, 2004 File No. 001-10153
Dear Ms. Ruhe:
We have reviewed your April 15, 2005 response letter and have the following 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.
Form 10-K for the year December 31, 2004
Financial Statements and Notes
Note 1 - Summary of Significant Accounting Policies, pages F-8 to F-
Provision for Environmental Remediation, page F-9
1. We understand from your disclosure the environmental liability relates to 30 acres of undeveloped land. Additionally, your response to our comment indicates you tested the recoverability of $143,000 in book value for the "affected parcel". In a supplemental response, please explain your basis for determining this parcel to be the lowest level for which impairment is to be evaluated. In your response, address how the environmental liability is independent from cash flows of Otay Land Company, LLC. Additionally, please advise us of the assumptions used in determining the recoverability of book value of the affected parcel if the entire environmental liability is limited to cash flows of this parcel. If the liability is not isolated to the cash flows of this parcel, advise us of your impairment evaluation with respect to the total carrying value of Otay land.
Comment Letter dated April 8, 2005
2. Please provide the acknowledgments regarding the Company`s responsibilities requested in our comment letter dated April 8, 2005.
You may contact Matthew Dowling, Staff Accountant, at (202) 824-5141 or me at (202) 824-5222 if you have questions. Please respond to the comments included in this letter within ten business days or tell us when you will provide us with a response. Please file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
April 20, 2005
Mail Stop 0409
VIA U.S. MAIL AND FAX (760) 918-8210
Ms. Erin Ruhe
VP, Treasurer and Controller
HomeFed Corporation
1903 Wright Place, Suite 220
Carlsbad, CA 92008
Re: HomeFed Corporation
Form 10-K for the year ended December 31, 2004
File No. 001-10153
Dear Ms. Ruhe:
We have reviewed your April 15, 2005 response letter and
have
the following 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.
Form 10-K for the year December 31, 2004
Financial Statements and Notes
Note 1 - Summary of Significant Accounting Policies, pages F-8 to
F-
10
Provision for Environmental Remediation, page F-9
1. We understand from your disclosure the environmental liability
relates to 30 acres of undeveloped land. Additionally, your
response
to our comment indicates you tested the recoverability of $143,000
in
book value for the "affected parcel". In a supplemental response,
please explain your basis for determining this parcel to be the
lowest level for which impairment is to be evaluated. In your
response, address how the environmental liability is independent
from
cash flows of Otay Land Company, LLC. Additionally, please advise
us
of the assumptions used in determining the recoverability of book
value of the affected parcel if the entire environmental liability
is
limited to cash flows of this parcel. If the liability is not
isolated to the cash flows of this parcel, advise us of your
impairment evaluation with respect to the total carrying value of
Otay land.
Comment Letter dated April 8, 2005
2. Please provide the acknowledgments regarding the Company`s
responsibilities requested in our comment letter dated April 8,
2005.
You may contact Matthew Dowling, Staff Accountant, at (202)
824-5141 or me at (202) 824-5222 if you have questions. Please
respond to the comments included in this letter within ten
business
days or tell us when you will provide us with a response. Please
file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
??
??
??
??
Homefed Corporation
April 21, 2005
Page 1 of 2
</TEXT>
</DOCUMENT>