On February 14, 2005, the Staff of the SEC Division of Corporation Finance (the Staff) publicly posted sample letters based on comment letters sent to certain registrants on two different topics. The Staff determined that sample letters should be made publicly available in order to promote wide-spread awareness on certain accounting issues and to provide examples of comments that other registrants should consider as they prepare future SEC filings, as applicable. The content of these two sample letters were as follows:  

• Statement of Cash Flow Presentation
  
  This sample letter communicates the Staff’s observations with respect to particular issues encountered by certain registrants related to SFAS No. 95, "Statement of Cash Flows." The letter specifically addressed the presentation of cash receipts from inventory sales in consolidated statements of cash flows. The Staff also emphasizes that appropriate classification and presentation of items in the statement of cash flows is more important than ever, because in certain instances, the statement is relied upon by analysts and investors as much as, if not more than, the statement of income. The Staff therefore encourages companies to put more time and effort into ensuring that the statement of cash flows, and related disclosure in the financial statement footnotes and in MD&A is meaningful and useful to users of the financial statements.
  
  The full text of the Staff’s observations and the related sample letter can be obtained on the SEC Web site at http://www.sec.gov/divisions/corpfin/acctdis030405.htm#P384_52979.
  
  If you have any additional questions regarding this sample letter, please contact Stephanie Hunsaker, Assistant Chief Accountant or Todd E. Hardiman, Associate Chief Accountant at (202)-942-2960.
  
  
• Oil and Gas Industry Issues
  
  This sample letter discusses the Staff's comments related to issues recently encountered by several registrants in the oil and gas industry. In the letter, the Staff addresses three main areas: buy-sell arrangements, accounting for suspended exploratory wells and accounting for Goodwill by a full-cost company disposing of a portion of a property. It is important to note that the Staff stated in the sample letter that their observations and disclosure guidance related to "buy-sell transactions are based on experience with transactions utilized in the petroleum industry, but may have application to non-petroleum products and other industries."
  
  The full text of the Staff’s observations and the related sample letter can be obtained on the SEC Web site at http://www.sec.gov/divisions/corpfin/guidance/oilgas021105.htm.
  
  If you have any additional questions regarding this sample letter, please contact Leslie Overton at (202) 942-2960 or Barry Stem at (202) 942-1870.