-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, MbB1q/Wnd9zsNJbFExO6v8sVx5xlOlIWb253B3CA7qEmJzF2J1jFu7CnQjqeVKUO 63Z7eHoBGx1T4MgsDQ6sTQ== 0000950134-07-002428.txt : 20070413 0000950134-07-002428.hdr.sgml : 20070413 20070208142906 ACCESSION NUMBER: 0000950134-07-002428 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20070208 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ALASKA COMMUNICATIONS SYSTEMS GROUP INC CENTRAL INDEX KEY: 0001089511 STANDARD INDUSTRIAL CLASSIFICATION: TELEPHONE COMMUNICATIONS (NO RADIO TELEPHONE) [4813] IRS NUMBER: 522126573 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 600 TELEPHONE AVENUE STREET 2: - CITY: ANCHORAGE STATE: AK ZIP: 99503 BUSINESS PHONE: 9072973000 MAIL ADDRESS: STREET 1: 600 TELEPHONE AVENUE STREET 2: - CITY: ANCHORAGE STATE: AK ZIP: 99503 FORMER COMPANY: FORMER CONFORMED NAME: ALEC HOLDINGS INC DATE OF NAME CHANGE: 19990624 CORRESP 1 filename1.htm corresp
 

February 6, 2007
Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
United States Securities and Exchange Commission
Washington, D.C. 20549
         
Re:
      Alaska Communications Systems Group, Inc.
 
      Form 10-K for Fiscal Year Ended December 31, 2005
 
      Filed March 9, 2006
 
        
 
      Form 10-Q for Fiscal Quarters ended June 30, 2006
 
      File No. 0-28167
Dear Sir,
In response to your letter of October 17, 2006 set forth herein is the response of Alaska Communications Systems Group, Inc. (“ACS”) or (“the Company”), to your request for clarification of one comment on our Form 10-Q for the Fiscal Quarter ended June 30, 2006.
     .
Form 10-Q, June 30, 2006
Financial Statements
8. Commitments and Contingencies, Page 15
  1.   Explain to us what you mean by “(t)he intrinsic value of the assets was determined to be the cash settlement of $1,979,000 received from Crest in closing the transaction”. Tell us if you determined that this value is the fair value of the assets from Crest and, if so, tell us how you determined the fair value. Also, please explain to us your basis in GAAP for your accounting consideration of guidance in paragraphs 13-16 of SFAS No. 114.
      The Company received the Crest assets and a cash settlement of $1,979,000. The Company determined that there is no observable market price for the Crest assets. Accordingly, the Company used a discounted cash flow method based on existing revenue contracts, potential future business and internal savings the Company could generate by using the asset, together with the stand alone costs of operating the asset, and determined the fair value of the Crest assets was nominal. The amount recognized as income was the cash settlement of $1,979,000 upon taking possession of the asset.

 

 

      The Company has reviewed the guidance provided in paragraphs 13-16 of SFAS No. 114 “Accounting by Creditors for Impairment of Loans” and concluded that, exclusive of the cash settlement, the estimated fair value of the assets received was nominal, and, accordingly, the Company’s accounting treatment is consistent with the provisions of FAS 114.
Sincerely,
  /s/ DAVID WILSON                      
David Wilson
Senior Vice President, Chief Financial Officer and Treasurer
Alaska Communications Systems Group, Inc.

 

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