Initial Letter Date |
Form filed |
Market Capitalization |
07/02/2012 |
10-K |
$ 426.29 M |
We note from page [xx] that during 2010 you adopted a plan of reorganization for tax - planning purposes in order to protect your substantial net operating losses. Please explain to us in more detail the nature of the reorganization, how you accounted for the reorganization and how it impacted your financial statements, including your accounting for your taxes under Topic 740 of the FASB Accounting Standards Codification. Please make sure your response cites the specific accounting literature you considered when accounting for and presenting the referenced transaction. |