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SEC Comment Letter for INSIGHT HEALTH SERVICES HOLDINGS CORP (CIK 0001145238) — Nov 5, 2004

INSIGHT HEALTH SERVICES HOLDINGS CORP (CIK 0001145238)
Date: Nov. 5, 2004 · CIK: 0001145238 · Accession: 0000000000-04-035607

AI Filing Summary & Sentiment

File numbers found in text: 333-75984

Date
November 4, 2004
Author
Jeffrey Riedler
Form
UPLOAD
Company
INSIGHT HEALTH SERVICES HOLDINGS CORP (CIK 0001145238)

Letter

Mail Stop 3-09 November 4, 2004 Marilyn U. MacNiven-Young, Esq. Executive Vice President and General Counsel InSight Health Services Holdings Corp. 26250 Enterprise Court, Suite 100 Lake Forest, California 92630

Re: InSight Health Services Holdings Corp. Annual Report on Form 10-K for the Year Ended 6/30/04 File Number 333-75984-12

Dear Ms. MacNiven-Young:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may 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

Management`s Discussion and Analysis of Financial Condition and Results of Operations, page 22

1. Refer to your response to comment 2 and the supplemental information provided regarding self-pay receivables. It appears that self-pay receivables are material to net income and thus we believe additional disclosure regarding your accounts receivable for payer classification and related allowances is important for an investors` understanding of your business.

Note 3. Summary of Significant Accounting Policies

b. Consolidated Financial Statements

2. We noted your response to our comment 6. Please refer to EITF 97- 2. Please tell us the following:

* if your interest in the partnership is unilaterally salable or transferable, * do you have exclusive authority with regards to compensation of all employees of the partnership, and * why the ability to jointly approve contracts in excess of $60,000 annually is not an operating factor that would preclude consolidation.

* * *

As appropriate, please amend your filing in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a response letter with your amendment that keys your responses to our comments. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR under the form type label CORRESP. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

You may contact Sasha Parikh at (202) 942-1962 or Mary Mast at (202) 942-1858 if you have questions regarding comments on the financial statements and related matters. Please contact Greg Belliston at (202) 824-5219 or me at (202) 942-1840 with any other questions.

Sincerely,
Jeffrey Riedler
Assistant Director

Show Raw Text
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Mail Stop 3-09

							November 4, 2004

Marilyn U. MacNiven-Young, Esq.
Executive Vice President and General Counsel
InSight Health Services Holdings Corp.
26250 Enterprise Court, Suite 100
Lake Forest, California 92630

Re:	InSight Health Services Holdings Corp.
	Annual Report on Form 10-K for the Year Ended 6/30/04
	File Number 333-75984-12

Dear Ms. MacNiven-Young:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your explanation.
In some of our comments, we may 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

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 22

1. Refer to your response to comment 2 and the supplemental
information provided regarding self-pay receivables.  It appears that
self-pay receivables are material to net income and thus we believe
additional disclosure regarding your accounts receivable for payer
classification and related allowances is important for an investors`
understanding of your business.

Note 3. Summary of Significant Accounting Policies

b. Consolidated Financial Statements

2. We noted your response to our comment 6.  Please refer to EITF 97-
2.  Please tell us the following:

* if your interest in the partnership is unilaterally salable or
transferable,
* do you have exclusive authority with regards to compensation of all
employees of the partnership, and
* why the ability to jointly approve contracts in excess of $60,000
annually is not an operating factor that would preclude
consolidation.

*	*	*

	As appropriate, please amend your filing in response to these
comments.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a response letter
with your amendment that keys your responses to our comments.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR under the form type label CORRESP.  Please
understand that we may have additional comments after reviewing your
amendment and responses to our comments.

	You may contact Sasha Parikh at (202) 942-1962 or Mary Mast at
(202) 942-1858 if you have questions regarding comments on the
financial statements and related matters.  Please contact Greg
Belliston at (202) 824-5219 or me at (202) 942-1840 with any other
questions.

							Sincerely,

							Jeffrey Riedler
							Assistant Director

cc:	Stephen C. Koval, Esq.
	Kaye Scholer LLP
	425 Park Avenue
	New York, New York 10022
Marilyn U. MacNiven-Young, Esq.
InSight Health Services Holdings Corp.
November 4, 2004
Page 1

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