SEC Comment Letter for HOMEFED CORP (CIK 0000833795) — May 3, 2005
HOMEFED CORP (CIK 0000833795)
Date: May 3, 2005 · CIK: 0000833795 · Accession: 0000000000-05-021418
AI Filing Summary & Sentiment
File numbers found in text: 001-10153
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 28, 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. In light of your disclosure on page F-9 that you allocate costs based on relative fair value rather than specific identification under paragraph 11 of SFAS 67, please tell us how the cash outflows of each parcel are largely independent in reaching your determination each parcel is the lowest level at which to evaluate impairment. In your response, please tell us at what level the environmental liability is assigned for evaluating impairment and why.
2. Your response to our comment states you estimate future net cash flows of Otay land to be over $150 million, which would exceed the carrying value of all Otay land and the environmental liability. Please relate and explain the estimate to historical sales per acre
of developable and mitigation Otay land. We note your historical sales per acre appear to be significantly less than what you estimate in your impairment test.
You may contact Matthew Dowling, Staff Accountant, at (202) 551-3467 or me at (202) 551-3403 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
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<TEXT>
May 3, 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 28, 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. In light of your disclosure on page F-9 that you allocate costs
based on relative fair value rather than specific identification
under paragraph 11 of SFAS 67, please tell us how the cash
outflows
of each parcel are largely independent in reaching your
determination
each parcel is the lowest level at which to evaluate impairment.
In
your response, please tell us at what level the environmental
liability is assigned for evaluating impairment and why.
2. Your response to our comment states you estimate future net
cash
flows of Otay land to be over $150 million, which would exceed the
carrying value of all Otay land and the environmental liability.
Please relate and explain the estimate to historical sales per
acre
of developable and mitigation Otay land. We note your historical
sales per acre appear to be significantly less than what you
estimate
in your impairment test.
You may contact Matthew Dowling, Staff Accountant, at (202)
551-3467 or me at (202) 551-3403 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
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Homefed Corporation
May 3, 2005
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