SEC Company Response from BEARD — Jun 15, 2005
BEARD CO /OK (CIK 0000909992)
Date: June 15, 2005 · CIK: 0000909992 · Accession: 0000909334-05-000199
AI Filing Summary & Sentiment
Letter
THE BEARD COMPANY Enterprise Plaza, Suite 320 5600 North May Avenue Oklahoma City, Oklahoma 73112 Fax (405) 842-9901 (405) 842-2333 June 15, 2005 Mr. Bret Johnson Staff Accountant Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549-0510
Re: Form 10-K for the fiscal year ended December 31, 2004 File No. 1-12396
Dear Mr. Johnson:
The following is offered in response to your letter of June 13, 2005 regarding the Form 10-K of The Beard Company:
SEC June 13, 2005 Comment No. 1 -------------------------------
Note 5 - Investments and Other Assets Investment in Cibola Corporation
As noted in our letters to the SEC dated May 10 and June 7, 2005, the Company owns 80% of the common stock of Cibola Corporation. The Company is entitled, however, under an allocation formula, to receive as its share of Cibola's financial income, a cash distribution of less than 10% of the separate Federal taxable income of Cibola during each year or portion thereof in which Cibola is a member of the consolidated Federal income tax group of which the Company is the parent. The preferred shareholders and the holders of 20% of the common have elected to leave the remaining net income in Cibola each year to enhance the ultimate rate of return to Cibola shareholders. In FY2004, Cibola reported financial net income of approximately $4,221,000; however, the Company's cash distribution under the agreed allocation formula was only approximately $290,000. This is the amount that the Company recorded as earnings in unconsolidated affiliates and as an increase in its investment in Cibola for the year 2004. The cash was distributed in January of 2005 and the Company's investment in Cibola was reduced. As previously noted, there is no risk to the Company's shareholders regarding this amount because the amount reported as earned and subsequently distributed is known by the time the financial statements are made public information.
Please acknowledge receipt hereof by returning one copy of this letter with your filing stamp endorsed thereon. A stamped, self-addressed envelope is enclosed for your convenience.
Sincerely,
THE BEARD COMPANY
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THE BEARD COMPANY
Enterprise Plaza, Suite 320
5600 North May Avenue
Oklahoma City, Oklahoma 73112
Fax (405) 842-9901
(405) 842-2333
June 15, 2005
Mr. Bret Johnson
Staff Accountant
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549-0510
Re: Form 10-K for the fiscal year
ended December 31, 2004
File No. 1-12396
Dear Mr. Johnson:
The following is offered in response to your letter of June 13, 2005 regarding
the Form 10-K of The Beard Company:
SEC June 13, 2005 Comment No. 1
-------------------------------
Note 5 - Investments and Other Assets
Investment in Cibola Corporation
As noted in our letters to the SEC dated May 10 and June 7, 2005, the Company
owns 80% of the common stock of Cibola Corporation. The Company is entitled,
however, under an allocation formula, to receive as its share of Cibola's
financial income, a cash distribution of less than 10% of the separate Federal
taxable income of Cibola during each year or portion thereof in which Cibola is
a member of the consolidated Federal income tax group of which the Company is
the parent. The preferred shareholders and the holders of 20% of the common have
elected to leave the remaining net income in Cibola each year to enhance the
ultimate rate of return to Cibola shareholders. In FY2004, Cibola reported
financial net income of approximately $4,221,000; however, the Company's cash
distribution under the agreed allocation formula was only approximately
$290,000. This is the amount that the Company recorded as earnings in
unconsolidated affiliates and as an increase in its investment in Cibola for the
year 2004. The cash was distributed in January of 2005 and the Company's
investment in Cibola was reduced. As previously noted, there is no risk to the
Company's shareholders regarding this amount because the amount reported as
earned and subsequently distributed is known by the time the financial
statements are made public information.
Please acknowledge receipt hereof by returning one copy of this letter with your
filing stamp endorsed thereon. A stamped, self-addressed envelope is enclosed
for your convenience.
Sincerely,
THE BEARD COMPANY
HERB MEE, JR.
Herb Mee, Jr. President and
Chief Financial Officer
HMJr/do
cc: Mr. Jerry A. Warren, Esq.
c/o McAfee & Taft
Tenth Floor
Two Leadership Square
Oklahoma City, OK 73102
Mr. Michael Gibson
c/o Cole & Reed, P.C.
531 Couch Drive, Suite 200
Oklahoma City, OK 73102-2251
Mr. W. M. Beard
Chairman of the Board
c/o The Beard Company
Mr. Jack A. Martine
Chief Accounting Officer
c/o The Beard Company
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