SEC Comment Letter for HAMMONS JOHN Q HOTELS LP (CIK 0000916536) — May 19, 2005
HAMMONS JOHN Q HOTELS LP (CIK 0000916536)
Date: May 19, 2005 · CIK: 0000916536 · Accession: 0000000000-05-024797
AI Filing Summary & Sentiment
Referenced dates: May 12, 2005
Letter
May 19, 2005 Mail Stop 0409 via U.S. Mail and Fax (417) 873-3503 Mr. Paul E. Muellner Chief Financial Officer John Q. Hammons Hotels, Inc. 300 John Q. Hammons Parkway, Suite 900 Springfield, MO 65806
Re: John Q. Hammons Hotels, Inc. Form10-K for the year ended December 31, 2004 File No. 1-13486 John Q. Hammons Hotels, LP Form 10-K for the year ended December 31, 2004 File No. 033-73340
Dear Mr. Mueller:
We have reviewed your response letter dated May 12, 2005 and have the following additional comments. In our comments, we ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise 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 on 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 ended December 31, 2004
Report of Independent Registered Public Accounting Firm, page 47 1. We note in your response to our previous comment 2 that the Company faxed a copy of the signed audit opinion with your response. It is noted that we did not receive a copy of the opinion in your previous fax and at this time we do not need a copy of the audit opinion, as we are relying on your representation that you obtained a signed copy as required by Regulation S-T.
Note 6 Commitments and Contingencies, page 65 2. We have considered your response to our previous comment 4 and note that whether the businesses are operating at a loss or whether the business has on operating profit after making rental payments are separate questions from whether the rental payments are the equivalent of fair market lease rates if the lessor were an independent third party. Please address the latter question in your next response.
Please respond to the comments included in this letter within ten business days. If you have any questions, you may contact Thomas Flinn, Staff Accountant, at (202) 551-3469 or the undersigned at (202) 551-3498 if you have questions.
Sincerely,
Linda Van Doorn
Senior Assistant Chief Accountant
Show Raw Text
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May 19, 2005
Mail Stop 0409 via U.S. Mail and Fax (417) 873-3503
Mr. Paul E. Muellner
Chief Financial Officer
John Q. Hammons Hotels, Inc.
300 John Q. Hammons Parkway, Suite 900
Springfield, MO 65806
Re: John Q. Hammons Hotels, Inc.
Form10-K for the year ended December 31, 2004
File No. 1-13486
John Q. Hammons Hotels, LP
Form 10-K for the year ended December 31, 2004
File No. 033-73340
Dear Mr. Mueller:
We have reviewed your response letter dated May 12, 2005 and
have the following additional comments. In our comments, we ask
you
to provide us with supplemental information so we may better
understand your disclosure. After reviewing this information, we
may
or may not raise 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 on 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 ended December 31, 2004
Report of Independent Registered Public Accounting Firm, page 47
1. We note in your response to our previous comment 2 that the
Company faxed a copy of the signed audit opinion with your
response.
It is noted that we did not receive a copy of the opinion in your
previous fax and at this time we do not need a copy of the audit
opinion, as we are relying on your representation that you
obtained a
signed copy as required by Regulation S-T.
Note 6 Commitments and Contingencies, page 65
2. We have considered your response to our previous comment 4 and
note that whether the businesses are operating at a loss or
whether
the business has on operating profit after making rental payments
are
separate questions from whether the rental payments are the
equivalent of fair market lease rates if the lessor were an
independent third party. Please address the latter question in
your
next response.
Please respond to the comments included in this letter
within
ten business days. If you have any questions, you may contact
Thomas
Flinn, Staff Accountant, at (202) 551-3469 or the undersigned at
(202) 551-3498 if you have questions.
Sincerely,
Linda Van Doorn
Senior Assistant Chief Accountant
John Q. Hammons Hotels, Inc
John Q. Hammons Hotels, LP
May 19, 2005
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