SEC Comment Letter for Outdoor Holding (POWW) — Aug 23, 2017
Outdoor Holding Co
Date: Aug. 23, 2017 · CIK: 0001015383 · Accession: 0000000000-17-029750
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 August 23, 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 Response dated August 8, 2017 File No. 001 -13101
Dear Mr. Wagenhals :
We have reviewed your August 8, 2017 response to our comment letter 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 comm ent applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 1 , 2017 letter .
Form 10 -Q for the quarter ended March 31, 2017
Note 3 – Vendor Notes Receivable, page 12
1. We note you have referenced ASC 805 -30-30-1 to support recording goodwill related to your successful bid for the collateral of the note re ceivable you held with ATAC. Please further clarify why you believe the application of the acquisition method under ASC 805 is appropriate in accounting for the foreclosure of the inventory and manufacturing equipment of ATAC rather than as an impairment of the note receivable under ASC 310 - 10-35-16 through 19 and 22. Please also discuss your consideration of ASC 805 -10-55- 20 through 23 regarding the settlement of the preexisting note with ATAC in determining your accounting for this transaction.
Fred W. Wagenhals Ammo, Inc. August 23, 2017 Page 2
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.
You may contact Myra Moosariparambil at (202) 423 -8539 o r me at (202) 551 -3650 with any questions.
Sincerely,
/s/Craig Arakawa
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Mail Stop 3561 August 23, 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 Response dated August 8, 2017 File No. 001 -13101 Dear Mr. Wagenhals : We have reviewed your August 8, 2017 response to our comment letter 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 comm ent applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 1 , 2017 letter . Form 10 -Q for the quarter ended March 31, 2017 Note 3 – Vendor Notes Receivable, page 12 1. We note you have referenced ASC 805 -30-30-1 to support recording goodwill related to your successful bid for the collateral of the note re ceivable you held with ATAC. Please further clarify why you believe the application of the acquisition method under ASC 805 is appropriate in accounting for the foreclosure of the inventory and manufacturing equipment of ATAC rather than as an impairment of the note receivable under ASC 310 - 10-35-16 through 19 and 22. Please also discuss your consideration of ASC 805 -10-55- 20 through 23 regarding the settlement of the preexisting note with ATAC in determining your accounting for this transaction. Fred W. Wagenhals Ammo, Inc. August 23, 2017 Page 2 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. You may contact Myra Moosariparambil at (202) 423 -8539 o r me at (202) 551 -3650 with any questions. Sincerely, /s/Craig Arakawa Craig Arakawa Accounting Branch Chief Office of Beverages, Apparel, and Mining