March 20, 2012
U.S. Securities and Exchange Commission BY EDGAR
100 F Street, N.E.
Washington, DC 20549
Attention: Kevin Woody
Accounting Branch Chief
Re: Oakridge Holdings, Inc.
Form 10-K
Filed October 13,2011
File No. 000-01937
Ladies and Gentlemen:
On behalf of Oakridge Holdings, Inc. ("Oakridge" or the "Company"), I am
pleased to submit this response to the comments of the Staff on the
above-referenced filings, as set forth in Mr. Woody's letter to me dated
March 8, 2012. For convenience, the Staff's numbered comments are set forth
below, followed by Oakridge's responses.
Oakridge hereby represents that (i) it is responsible for the adequacy and
accuracy of the disclosure in the filings, (ii) Staff comments or changes to
disclosure in response to Staff comments in the filings reviewed by the Staff
do not foreclose the Securities and Exchange Commission from taking any action
with respect to the filings and (iii) Oakridge may not assert Staff comments
as a defense in any proceeding initiated by the Securities and Exchange
Commission or any person under the federal securities laws of the United
States.
Form 10-K for the year ended June 30, 2011
Financial Statements
10. Income Taxes
Comment: We have considered your response to our prior comment 1. Please
provide us with a more detailed explanation of the "General Business Credit"
referenced in your letter. Given that you amended your 2010 tax return to
claim this credit for activities for the periods 2004 to 2010, explain to us
how you determined there was not an error in your previously issued financial
statements. Finally, tell us the balance of the related deferred tax asset for
each quarterly period subsequent to June 30, 2011.
Response: In July, 2012 we were approached by a consulting firm regarding a
study of the Company's research and development activities. The results of
that study indicated the Company qualified for a research and development
credits as follows:
Tax Year Fiscal Year R&D Credits
1998 6/30/1999 $ 9,198
1999 6/30/2000 $ 9,690
2003 6/30/2004 $24,698
2004 6/30/2005 $27,946
2005 6/30/2006 $30,129
2006 6/30/2007 $16,916
2007 6/30/2008 $16,916
2008 6/30/2009 $ 5,659
2009 6/30/2010 $26,563
2010 6/30/2011 $17,081
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$184,796
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At the time of our filing we did not consider this an error in our previously
issued financial statements because the research and development credits
were the result of the consultant's study performed in 2011.
If we can facilitate the Staff's review of this letter, or if the Staff has
any questions on any of the information set forth herein, please telephone
me at (651) 454-5112. My fax number is (651) 454-5143.
Sincerely,
/s/ Robert C. Harvey
Robert C. Harvey
President and Chief Executive Officer