SEC Comment Letter for INTRA ASIA ENTERTAINMENT CORP (CIK 0001081206) — Jul 13, 2005
INTRA ASIA ENTERTAINMENT CORP (CIK 0001081206)
Date: July 13, 2005 · CIK: 0001081206 · Accession: 0000000000-05-035700
AI Filing Summary & Sentiment
File numbers found in text: 333-75297
Letter
Mail Stop 3561 Via US Mail and Facsimile Mr. Duo Wang Chief Financial Officer 1111 Corporate Center Road Suite 203B Monterey Park, California 91754
Re: Intra-Asia Entertainment Corporation Form 10-KSB for the fiscal year ended December 31, 2004 Commission file # 333-75297:
Dear Mr. Wang:
We have reviewed your July 11, 2005 response letter and have the following comments. Where expanded or revised disclosure is requested, you may comply with these comments in future filings. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. We also ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. We look forward to working with you in these respects and welcome any questions you may have about any aspects of our review.
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Form 10-KSB for the year ended December 31, 2004
Note 6. Related Party Transactions, page F-17
We note from your response to comment 7 that you recognized a gain of $488,129 on the return of the land usage right, which represented the excess paid by your partner over the carrying amount. However, we are still unclear as to the nature and amount of the consideration received in this transaction. Please tell us the nature and amount of the consideration received in exchange for relinquishment of the land usage right. Also, we believe that because this transaction was with a related party, and there is no independent appraisal of the land, this transaction may be more appropriately accounted for as a contribution to equity, rather than a gain in the statement of operations. Please revise or advise us of why you believe your current treatment is appropriate.
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As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your responses to our comments and provides any requested supplemental information.
You may contact Claire Lamoureux at 202-551-3301 or Linda Cvrkel at 202-551-3813 if you have questions. Sincerely,
Joseph A. Foti Senior Assistant Chief Accountant ??
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Mr. Duo Wang Intra-Asia Entertainment Corporation July 13, 2005 Page 1
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> July 13, 2005 Mail Stop 3561 Via US Mail and Facsimile Mr. Duo Wang Chief Financial Officer 1111 Corporate Center Road Suite 203B Monterey Park, California 91754 Re: Intra-Asia Entertainment Corporation Form 10-KSB for the fiscal year ended December 31, 2004 Commission file # 333-75297: Dear Mr. Wang: We have reviewed your July 11, 2005 response letter and have the following comments. Where expanded or revised disclosure is requested, you may comply with these comments in future filings. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. We also ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. We look forward to working with you in these respects and welcome any questions you may have about any aspects of our review. * * * * * * * * * * * * * * * * * * * * * * * Form 10-KSB for the year ended December 31, 2004 Note 6. Related Party Transactions, page F-17 We note from your response to comment 7 that you recognized a gain of $488,129 on the return of the land usage right, which represented the excess paid by your partner over the carrying amount. However, we are still unclear as to the nature and amount of the consideration received in this transaction. Please tell us the nature and amount of the consideration received in exchange for relinquishment of the land usage right. Also, we believe that because this transaction was with a related party, and there is no independent appraisal of the land, this transaction may be more appropriately accounted for as a contribution to equity, rather than a gain in the statement of operations. Please revise or advise us of why you believe your current treatment is appropriate. * * * * * * * * * * * * * * * * * * * * * * * As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your responses to our comments and provides any requested supplemental information. You may contact Claire Lamoureux at 202-551-3301 or Linda Cvrkel at 202-551-3813 if you have questions. Sincerely, Joseph A. Foti Senior Assistant Chief Accountant ?? ?? ?? ?? Mr. Duo Wang Intra-Asia Entertainment Corporation July 13, 2005 Page 1 </TEXT> </DOCUMENT>