SEC Comment Letter for NORTEL INVESTMENTS INC (CIK 0000877691) — Sep 28, 2005
NORTEL INVESTMENTS INC (CIK 0000877691)
Date: Sept. 28, 2005 · CIK: 0000877691 · Accession: 0000000000-05-050077
AI Filing Summary & Sentiment
Referenced dates: August 18, 2005, September 16, 2005
Letter
Mail Stop 3561 September 28, 2005 Mr. Jose Gustavo Pozzi General Manager and Sole Officer Nortel Inversora S.A. Alicia Moreau de Justo 50 Piso 11 C1107AAB-Buenos Aires Argentina
Re: Nortel Inversora S.A. Form 20-F for Fiscal Year Ended December 31, 2004 Filed June 29, 2005 File No. 1-14270
Dear Mr. Pozzi:
We have reviewed your amendment and supplemental response letter dated September 16, 2005 as well as your filing and have the following comments. As noted in our comment letter dated August 18, 2005, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
Form 20-F for Fiscal Year Ended December 31, 2004
8. Debt of the Telecom Group 8.1. The Telecom Group`s short-term and long-term debt, page F-24
1. We note your response to comment 10 and your statement that as a result of this tender offer, the Company purchased certain outstanding debt with a face value of approximately US$292 million, for a total purchase price of approximately US$161 million. Tell us the carrying value of the debt at the time of transaction. Based on this statement tell us in detail how you calculated a gain of US$376. Please cite specific US GAAP literature used.
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please file your response in EDGAR. You may contact Inessa Berenbaum, Staff Accountant, at (202) 551-3371 or Ivette Leon, Assistant Chief Accountant, at (202) 551-3351 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 with any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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<TYPE>LETTER
<SEQUENCE>1
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<TEXT>
Mail Stop 3561
September 28, 2005
Mr. Jose Gustavo Pozzi
General Manager and Sole Officer
Nortel Inversora S.A.
Alicia Moreau de Justo 50
Piso 11
C1107AAB-Buenos Aires
Argentina
Re: Nortel Inversora S.A.
Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 29, 2005
File No. 1-14270
Dear Mr. Pozzi:
We have reviewed your amendment and supplemental response
letter dated September 16, 2005 as well as your filing and have
the
following comments. As noted in our comment letter dated August
18,
2005, we have limited our review to your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.
Form 20-F for Fiscal Year Ended December 31, 2004
8. Debt of the Telecom Group
8.1. The Telecom Group`s short-term and long-term debt, page F-24
1. We note your response to comment 10 and your statement that as
a
result of this tender offer, the Company purchased certain
outstanding debt with a face value of approximately US$292
million,
for a total purchase price of approximately US$161 million. Tell
us
the carrying value of the debt at the time of transaction. Based
on
this statement tell us in detail how you calculated a gain of
US$376.
Please cite specific US GAAP literature used.
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please file
your
response in EDGAR. You may contact Inessa Berenbaum, Staff
Accountant, at (202) 551-3371 or Ivette Leon, Assistant Chief
Accountant, at (202) 551-3351 if you have questions regarding
comments on the financial statements and related matters. Please
contact me at (202) 551-3810 with any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Jose Gustavo Pozzi
General Manager and Sole Officer
September 28, 2005
Page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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