THE INTERGROUP CORPORATION
10940 Wilshire Blvd., Suite 2150
Los Angeles, CA 90024
Telephone: (310) 889-2500
Facsimile: (310) 889-2525
Via EDGAR
January 13, 2010
Robert Telewicz
Senior Staff Accountant
Howard Efron
Staff Accountant
Securities and Exchange Commission
Division of Corporation Finance, Mail Stop 3010
Washington, D.C. 20549
Re: The InterGroup Corporation.
Form 10-KSB for the fiscal year ended June 30, 2008
File No. 001-10324
Dear Mr. Telewicz and Mr. Efron:
This letter is a supplemental response to your comment letter dated October 1,
2009 regarding the Form 10-KSB for the fiscal year ended June 30, 2008 of The
InterGroup Corporation ("InterGroup" or the "Company"). Our response below
corresponds to the comment set forth in your letter. For convenience, we have
set forth the comment or question asked prior to our response.
Form 10-KSB for the fiscal year ended June 30, 2008
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Financial Statements
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Notes to Consolidated Financial Statements
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Note 1 - Business and Significant Accounting Policies and Practices
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Minority Interest, page 40
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1. We note your response to our prior comment one in your correspondence
letters dated as of August 24, 2009 and September 25, 2009 and we are unable to
agree with your position. It does not appear that the limited partners have a
contractual obligation to fund the accumulated deficit in Justice Enterprises,
Inc. As such, we continue to believe these losses should be charged to the
majority interest in accordance with paragraph 15 of ARB 51. Please revise your
financial statements accordingly. Additionally, please upload to Edgar copies
of the seven agreements which you provided to the Staff for its consideration
in this matter.
RESPONSE:
In response to the Staff's request that the Company upload to Edgar copies of
the seven agreements which were previously provided to the Staff for its
consideration, we have attached copies of those agreements to this supplemental
response for your files.
If you require further information or have further comments, please feel free
to call me at my direct number at (310) 889-2511 or you can reach me at my
direct facsimile number (310) 496-1606.
Sincerely,
/s/ David T. Nguyen
David T. Nguyen
Treasurer and Controller
Principal Financial Officer
cc: John V. Winfield
Michael G. Zybala
Audit Committee
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