July 14, 2005
Mr. Joseph B. Feiten
Chief Financial Officer
Tipperary Corporation
633 Seventeenth Street, Suite 1550
Denver, Colorado 80202
Re: Tipperary Corporation
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 24, 2005
File No. 001-07796
Dear Mr. Feiten:
We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our 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 information so we may better understand
your
disclosure. After reviewing this information, we may 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 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 for the Fiscal Year Ended December 31, 2004
Financial Statements
Consolidated Balance Sheets, page 30
1. Please revise your disclosure to address each of the following
as
required by Rule 4-10(c)(7)(ii) of Regulation S-X:
* Separate disclosure on the face of the balance sheet of the
aggregate of the capitalized costs of unproved properties and
major
development projects that are excluded from the capitalized costs
being amortized;
* A description in the notes to the financial statements of the
current status of the significant properties or projects involved,
including the anticipated timing of the inclusion of the costs in
the
amortization computation;
* A table that shows, by category of cost, the total costs
excluded
as of the most recent fiscal year; and the amounts of such
excluded
costs incurred in each of the three most recent fiscal years and
in
the aggregate for any earlier fiscal years in which the costs were
incurred. Please refer to the Rule for a description of the type
of
costs to be disclosed.
Note 13-Operations By Geographic Area, page 52
2. Please disclose total assets for each reportable segment as
required by paragraph 27 of SFAS 131.
Note 14-Supplementary Information on Oil and Gas Operations, page
54
3. Please revise your disclosure to comply with the disclosure
requirements of SFAS 69 as there is no provision for the line item
"Capitalized interest costs" in paragraph 21 or Illustration 2 of
SFAS 69.
Note 15-Quarterly Results of Operations, page 60
4. We note that you have not included depreciation relating to
property, plant and equipment in your determination of gross
profit.
Please revise your calculation of gross profit to follow a full
absorption costing principle and include all costs and expenses
associated directly with or allocated to your products sold. As
such
these costs and expenses include inventoriable costs of assets
incident to or necessary for production or manufacturing,
including
applicable depreciation, depletion and amortization. Refer to
Item
302 of Regulation S-K.
Engineering Comments
Estimates of Oil and Gas Reserves (Unaudited), page 56
5. In the last two years you have approximately doubled your
reserves, primarily in Australia, through discoveries and
extensions
but you do not provide any disclosure to investors on the nature,
location or timing of when these added reserves may be monetized.
Please provide to us the details of your largest reserve increases
in
each of the last two years. With a view toward enhanced
disclosure,
provide us with draft language on these reserve additions that you
plan to provide to investors in an amendment or in future filings.
Closing Comments
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Jennifer Goeken at (202) 551-3721, or Jill
Davis, Branch Chief, at (202) 551-3683 if you have questions
regarding comments on the financial statements and related
matters.
You may contact James Murphy, Petroleum Engineer, at (202) 551-
3703
with questions about engineering comments. Please contact me at
(202) 551-3740 with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
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Mr. Joseph B. Feiten
Tipperary Corporation
July 14, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010