January 13, 2020
Robert Knoth
Chief Financial Officer
IEH Corporation
140 58th Street, Suite 8E
Brooklyn, New York 11220
Re: IEH Corporation
Form 10-K for the Fiscal Year Ended March 29, 2019
Filed July 12, 2019
File No. 000-05278
Dear Mr. Knoth:
We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.
After reviewing your response to these comments, we may have additional
comments.
Form 10-K for the Fiscal Year Ended March 29, 2019
Management's Report on Internal Control over Financial Reporting, page 23
1. Please include disclosure in your future filings of the COSO framework
(e.g. 2013) used
to evaluate the effectiveness of your internal control over financial
reporting.
Item 9A. Controls and Procedures
Changes in Internal Control over Financial Reporting, page 24
2. Please refer to Item 308(C) of Regulation S-K and provide disclosure of
whether or not
any changes occurred during your last fiscal quarter, that materially
affected or is
reasonably likely to materially affect your internal control over
financial reporting. It is
unclear from your disclosure if the changes you mention were implemented
in your last
fiscal quarter or at other times. We note your disclosure indicates the
Audit Committee
Robert Knoth
FirstName LastNameRobert Knoth
IEH Corporation
Comapany NameIEH Corporation
January 13, 2020
Page 2
January 13, 2020 Page 2
FirstName LastName
was formed on November 27, 2018, which appears to represent a change
in your third
fiscal quarter.
Financial Statements
Report of Independent Registered Public Accounting Firm , page 39
3. Please have your independent registered public accounting firm provide
you with an audit
opinion that provides audit coverage for the years ended March 29,
2019 and March 30,
2018. Please file an amendment to include the revised report along
with updated
certifications. Refer to Rule 8-02 of Regulation S-X for guidance.
Balance Sheet, page 40
4. We note that you reflect $54,489 in other assets on your balance sheet
for both fiscal years
ended 2019 and 2018. Please explain to us what this asset represents
and why the balance
remains unchanged.
Liabilities and Stockholders' Equity, page 41
5. We note $348,230 of "Customer advance payments" as of March 29, 2019
reflected on
your balance sheet. Please explain to us the nature of the advance
payments. As part of
your response, please explain to us why the disclosure requirements
under ASC 606-10-
50-8 are not applicable.
Notes to Financial Statements
Note 7 Income Taxes, page 50
6. You disclosed that your company accounts for deferred income tax
assets or liabilities
under ASC 740. Please address the following:
Please revise to disclose the components of the net deferred tax
liability or asset in
accordance with paragraphs 2 through 5 of ASC 740-10-50.
Please explain to us where on the balance sheet you recorded
deferred tax assets and
deferred tax liabilities.
Please disclose a reconciliation using percentages or dollar
amounts of the reported
amount of income tax expense attributable to continuing
operations for the year to the
amount of income tax expense that would result from applying
domestic federal
statutory tax rates. Refer to ASC 740-10-50-12.
Robert Knoth
IEH Corporation
January 13, 2020
Page 3
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Andi Carpenter at 202-551-3645 or Kevin Stertzel at
202-551-3723 if
you have questions regarding comments.
FirstName LastNameRobert Knoth Sincerely,
Comapany NameIEH Corporation
Division of
Corporation Finance
January 13, 2020 Page 3 Office of
Manufacturing
FirstName LastName