Constar International Inc. |  | |
One Crown Way | ||
Philadelphia, PA 19154-4599 | ||
Main Phone: (215) 552-3700 |
May 30, 2008
Mr. Rufus Decker
Accounting Branch Chief
United States
Securities and Exchange Commission
100F Street, N.E., Stop 7010
Washington, D.C. 20549
| RE: | FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2007 | |
| File No. 0-16496 |
Dear Mr. Decker:
The following supplements my discussion with Jeffrey Gordon of your office.
Financial Statements
Consolidated Statements of Cash Flows, page 50
3. Please help us to understand how you reached your decision related to the classification of the change in the bank overdraft. See Section 1300.15 of the AICPA’s Technical Questions and Answers.
Response of May 5, 2008:
We had no bank overdrafts on December 31st of 2007 or 2006. We have presented the book overdrafts in this manner since the book overdrafts represent the reinstatement of accounts payable and do not result in cash changing hands or credit being extended by a financial institution.
Supplemental response:
A book overdraft does not result in cash changing hands or credit being extended by a financial institution, therefore, a book overdraft does not constitute “proceeds from short-term borrowings” per FAS 95, par. 19.b and, thus is not a financing activity.
If you have any questions, please feel free to contact me at (215) 552-3707 orwsobon@constar.net. Our fax number is (215) 552-3715.
| Very truly yours, |
/S/ Walter S. Sobon |
| Walter S. Sobon |
| Executive Vice President and Chief Financial Officer |