Initial Letter Date |
Form filed |
Market Capitalization |
09/12/2012 |
10-K |
$ 1,010 M |
We note that prior to September 30, 2010 you maintained a full valuation allowance for your net deferred tax assets, since the likelihood of realization of those assets had not become more likely than not. Effective September 30, 2010 you believed that sufficient positive evidence existed from historical operations and future income projections to conclude that it was more likely than not to fully realize your federal deferred tax assets and to partially realize your state of California deferred tax assets. Please provide a more detailed explanation as to how you determined it is more likely than not that you will realize total deferred tax assets. Please ensure your disclosures address each of the following points, as appropriate: To the extent that you are relying on future pre-tax income, please disclose the amount of pre-tax income that needs to be generated to realize your deferred tax assets. Please also include an explanation of the anticipated future trends included in your projections of future taxable income. If you are relying on the reversal of existing deductible temporary differences to support the realizability of your deferred tax assets, please disclose that the deferred tax liabilities you are relying on are of the same character and will reverse in both the same period and jurisdiction as the temporary differences giving rise to the deferred tax. If you are also relying on tax-planning strategies, please disclose the nature of your tax planning strategies, how each strategy supports the realization of deferred tax assets, the amount of the shortfall that each strategy covers, and any uncertainties, risks, or assumptions related to these tax-planning strategies. Please provide us with the disclosures you intend to include in future filings. Refer to ASC 740-10-30-16 through 30-25 and Section 501.14 of the Financial Reporting Codification for guidance. |