SEC Comment Letter for Outdoor Holding (POWW) — Aug 1, 2017
Outdoor Holding Co
Date: Aug. 1, 2017 · CIK: 0001015383 · Accession: 0000000000-17-026984
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Mail Stop 3561 August 1, 2017 Via E -mail Fred W. Wagenhals Chief Executive Officer Ammo, Inc. 6401 East Thomas Road #106 Scottsdale, AZ 85251 Re: Ammo, Inc. Form 10 -K for the Year Ended December 31, 2016 Filed March 16, 2017 File No. 001 -13101 Dear Mr. Wagenhals : We have limited our review of your filing to the financial statements and related disclosures and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment app lies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment , we may have additional comments. Form 10 -Q for the quarter ended March 31, 2017 Note 3 – Vendor Notes Receivable, page 12 1. We note you have recorded $1.77 million of goodwill as a result of your successful credit bid for the collateral related to the note receivable you held with ATAC. Please tell us your basis for recording goodwill related to this transaction, citing t he authoritative literature that supports your accounting. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff . Fred W. Wagenhals Ammo, Inc. August 1, 2017 Page 2 You may contact Myra Moosariparambil at (202) 423 -8539 or me at (202) 551 -3650 with any questions. Sincerely, /s/Craig Arakawa Craig Arakawa Accounting Branch Chief Office of Beverages, Apparel, and Mining