-----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, Wb2PNOJ3Uko+AQ3ESAoBwTjdLVHo7FTmWKmpOYNbMfxuWpoDbLTXeaad5TI+VEk7 yPCtpgomjjd7b1Kep2uz9A== 0000000000-05-046652.txt : 20060816 0000000000-05-046652.hdr.sgml : 20060816 20050909120550 ACCESSION NUMBER: 0000000000-05-046652 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050909 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: TIPPERARY CORP CENTRAL INDEX KEY: 0000098410 STANDARD INDUSTRIAL CLASSIFICATION: CRUDE PETROLEUM & NATURAL GAS [1311] IRS NUMBER: 751236955 STATE OF INCORPORATION: TX FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 633 17TH ST STE 1550 CITY: DENVER STATE: CO ZIP: 80202 BUSINESS PHONE: 3032939379 MAIL ADDRESS: STREET 1: 633 SEVENTEENTH ST STREET 2: SUITE 1550 CITY: DENVER STATE: CO ZIP: 80202 FORMER COMPANY: FORMER CONFORMED NAME: TIPPERARY LAND & EXPLORATION CORP DATE OF NAME CHANGE: 19730522 FORMER COMPANY: FORMER CONFORMED NAME: TIPPERARY LAND CORP DATE OF NAME CHANGE: 19690521 LETTER 1 filename1.txt September 9, 2005 Mr. Joseph B. Feiten Chief Financial Officer Tipperary Corporation 633 Seventeenth Street, Suite 1550 Denver, Colorado 80202 Re: Tipperary Corporation Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 24, 2005 Response Letter Dated September 6, 2005 File No. 001-07796 Dear Mr. Feiten: We have reviewed your response letter and have the following comment. We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to our comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. Form 10-K for the Fiscal Year Ended December 31, 2004 Engineering Comment Estimates of Oil and Gas Reserves (Unaudited), page 56 1. Regarding your response number 5, monetization of the reserves booked in 2004 will not begin for approximately 10 years while the monetization of reserves booked in 2003 will begin in 2009. Please provide the basis for declaring these reserves to be proved at this time and explain to us the gas market that exists for possible monetization of these reserves sooner. Describe to us the approved gas contracts that you have in place for both the reserves added in 2003 and 2004, including the annual volumes to be delivered and sold, the purchasers of the gas and the gas price you will receive. Closing Comments As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your response to our comment. You may contact James Murphy, Petroleum Engineer, at (202) 551- 3703 with questions about engineering comments. Please contact me at (202) 551-3740 with any other questions. Sincerely, H. Roger Schwall Assistant Director ?? ?? ?? ?? Mr. Joseph B. Feiten Tipperary Corporation September 9, 2005 Page 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION 100 F Street, NE WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE MAIL STOP 7010 -----END PRIVACY-ENHANCED MESSAGE-----