-----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, H48O8n38eiFNOKMGE6ly940nuCUAMPtRfBleeCDCGQflS1bS4Qc7G6JcWqPcR1L2 rzMIx+Vg4dis6++jD/wX7w== 0000950135-07-006918.txt : 20080117 0000950135-07-006918.hdr.sgml : 20080117 20071109165228 ACCESSION NUMBER: 0000950135-07-006918 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20071109 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TJX COMPANIES INC /DE/ CENTRAL INDEX KEY: 0000109198 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-FAMILY CLOTHING STORES [5651] IRS NUMBER: 042207613 STATE OF INCORPORATION: DE FISCAL YEAR END: 0127 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 770 COCHITUATE RD CITY: FRAMINGHAM STATE: MA ZIP: 01701 BUSINESS PHONE: 508-390-2662 MAIL ADDRESS: STREET 1: 770 COCHITUATE ROAD CITY: FRAMINGHAM STATE: MA ZIP: 01701 FORMER COMPANY: FORMER CONFORMED NAME: ZAYRE CORP DATE OF NAME CHANGE: 19890625 CORRESP 1 filename1.htm corresp
 

November 9, 2007
Via EDGAR
U.S. Securities and Exchange Commission
Division of Corporate Finance
Washington, D.C. 20549-7010
         
 
  Attention:   Mr. William Choi, Branch Chief
 
      Ms. Yong Kim, Division of Corporation Finance
     
Re:
  Form 10-K for the Fiscal Year Ended January 27, 2007 Filed on March 28, 2007
 
  File No. 1-4908
Dear Mr. Choi and Ms. Kim:
          We have reviewed your additional comment letter dated October 31, 2007 and provide the following response to your comment.
     
1.
  Comment:
 
    
 
  Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 25
 
    
 
  We have reviewed your response to prior comment 1 in our letter dated August 16, 2007 and note that you believe that all the adjusted items for 2006 and 2005 are one-time charges or gains and are not of a nature that is reasonably likely to recur within two years or were incurred in the prior two years. If our understanding of your response is correct, please explain your adjustments in both 2005 and 2006 to correct for an accounting error. Although one correction was for leases and the other for taxes, we believe the nature of the adjustments are the same. Also, we do not agree with your position that accounting adjustments from changes in laws, payments under employment agreements, business closure expenses and litigation settlements are-one-time charges or gains. We believe the nature of these charges and gains make them reasonably likely to recur within two years. If you can provide additional information that would help support your position, please do so, otherwise, we would expect these non-GAAP measures to be removed from future filings.
 
    
 
  Response:
 
    
 
  We respectfully disagree with the staff and continue to believe that our presentation in our Form 10-K for fiscal 2007 of adjustments to income for continuing operations for fiscal 2005 and 2006 is consistent with Item 10(e) of Regulation S-K. Nonetheless, we will not adjust income from continuing operations to exclude the cost or benefit of the deferred tax liability correction, repatriation income benefit, cumulative lease accounting charge, executive resignation agreements, e-commerce business discontinuance, the 2005 hurricanes and the VISA/MasterCard antitrust litigation settlement in our future filings.
Very Truly Yours,
/s/ Nirmal K. Tripathy
The TJX Companies, Inc.
By: Nirmal K. Tripathy
Chief Financial Officer
     
CC:
  Mary E. Weber, Ropes & Gray LLP

 

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