-----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, Q74JkUW0pYlWIPjhZYY2g9JKOX7JHLgixHffWOGjdHuv32/YIHZu7/tUTEQPolM1 wodr1JAOLKd9scFn0stZRQ== 0000278041-08-000002.txt : 20080822 0000278041-08-000002.hdr.sgml : 20080822 20080103171338 ACCESSION NUMBER: 0000278041-08-000002 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20080103 FILER: COMPANY DATA: COMPANY CONFORMED NAME: INTERNATIONAL SHIPHOLDING CORP CENTRAL INDEX KEY: 0000278041 STANDARD INDUSTRIAL CLASSIFICATION: DEEP SEA FOREIGN TRANSPORTATION OF FREIGHT [4412] IRS NUMBER: 362989662 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11 NORTH WATER STREET STREET 2: SUITE # 18290 CITY: MOBILE STATE: AL ZIP: 36602 BUSINESS PHONE: 2512439100 MAIL ADDRESS: STREET 1: P.O. BOX 2004 CITY: MOBILE STATE: AL ZIP: 36652 CORRESP 1 filename1.htm seccommentresponse1308.htm
 

January 3, 2008


Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549
 

 
RE:           International Shipholding Corporation
Form 10-K for the fiscal year ended December 31, 2006
Filed March 9, 2007
Commission File No. 001-10852
 

 
Dear Sir or Madam:

By letter dated December 21, 2007 (the “Comment Letter”) from the Staff to International Shipholding Corporation, the Staff provided certain comments with respect to the Form 10-K Annual Report for the fiscal year ended December 31, 2006.  In responding to those comments, we have reproduced below the full text of the Staff’s comments followed by our response.  In this letter, the terms “we,” “us,” “our,” and “the Company” refer to International Shipholding Corporation and its subsidiaries.


Form 10-K for the year ended December 31, 2006

Comment 1:

We note from your amended Form 10-K includes the audited financial statements of BSH for the year ended December 31, 2005 and the unaudited financial statements of BSH for the year ended December 31, 2004 and the nine months ended September 30, 2006. Please note that financial statements filed under Rule 3-09 of Regulation S-X whether audited or unaudited, should include a complete set of financial statements. Please revise to include the statements of cash flows, statements of changes in stockholders equity, and if possible, notes to the financial statements for year ended December 31, 2004 and nine months ended September 30, 2006.



 
Response:

In connection with filing our Form 10-K Annual Report for the fiscal year ended December 31, 2007, we will include a complete set of financial statements for BSH, including notes, for year ended December 31, 2004.  However, the only BSH financial statements that we have for nine months ended September 30, 2006 are the unaudited Balance Sheet and Statement of Income, which we have previously filed.  As we have previously reported, we have requested additional information from BSH officers, but were denied. Moreover, BSH has no legal or contractual commitment to provide additional data.  As such, we believe we have taken all steps within our  reasonable control  to provide information under Regulation S-X.

If there are any other questions regarding the above response, please do not hesitate to contact me at (251)243-9082.





                                Sincerely yours,

                                                                 INTERNATIONAL SHIPHOLDING CORPORATION

                               /s/ Manuel G. Estrada
 Manuel G. Estrada
 Vice President and Chief Financial Officer


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