-----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, JxLbtCtI/RCnxXMa73q9xlS+FwWWhFO1A+wC9ygaAJbFPr5mwlzSAYKkm3u7Tpul aDC36QvGR75shl/E/tJtVg== 0001157523-10-000149.txt : 20100308 0001157523-10-000149.hdr.sgml : 20100308 20100113141954 ACCESSION NUMBER: 0001157523-10-000149 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100113 FILER: COMPANY DATA: COMPANY CONFORMED NAME: INTERGROUP CORP CENTRAL INDEX KEY: 0000069422 STANDARD INDUSTRIAL CLASSIFICATION: OPERATORS OF APARTMENT BUILDINGS [6513] IRS NUMBER: 133293645 STATE OF INCORPORATION: DE FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 10940 WILSHIRE BLVD. STREET 2: SUITE 2150 CITY: LOS ANGELES STATE: CA ZIP: 90024 BUSINESS PHONE: (310) 889-2500 MAIL ADDRESS: STREET 1: 10940 WILSHIRE BLVD. STREET 2: SUITE 2150 CITY: LOS ANGELES STATE: CA ZIP: 90024 FORMER COMPANY: FORMER CONFORMED NAME: MUTUAL REAL ESTATE INVESTMENT TRUST DATE OF NAME CHANGE: 19860408 CORRESP 1 filename1.txt THE INTERGROUP CORPORATION 10940 Wilshire Blvd., Suite 2150 Los Angeles, CA 90024 Telephone: (310) 889-2500 Facsimile: (310) 889-2525 Via EDGAR January 13, 2010 Robert Telewicz Senior Staff Accountant Howard Efron Staff Accountant Securities and Exchange Commission Division of Corporation Finance, Mail Stop 3010 Washington, D.C. 20549 Re: The InterGroup Corporation. Form 10-KSB for the fiscal year ended June 30, 2008 File No. 001-10324 Dear Mr. Telewicz and Mr. Efron: This letter is a supplemental response to your comment letter dated October 1, 2009 regarding the Form 10-KSB for the fiscal year ended June 30, 2008 of The InterGroup Corporation ("InterGroup" or the "Company"). Our response below corresponds to the comment set forth in your letter. For convenience, we have set forth the comment or question asked prior to our response. Form 10-KSB for the fiscal year ended June 30, 2008 - --------------------------------------------------- Financial Statements - -------------------- Notes to Consolidated Financial Statements - ------------------------------------------ Note 1 - Business and Significant Accounting Policies and Practices - ------------------------------------------------------------------- Minority Interest, page 40 - -------------------------- 1. We note your response to our prior comment one in your correspondence letters dated as of August 24, 2009 and September 25, 2009 and we are unable to agree with your position. It does not appear that the limited partners have a contractual obligation to fund the accumulated deficit in Justice Enterprises, Inc. As such, we continue to believe these losses should be charged to the majority interest in accordance with paragraph 15 of ARB 51. Please revise your financial statements accordingly. Additionally, please upload to Edgar copies of the seven agreements which you provided to the Staff for its consideration in this matter. RESPONSE: In response to the Staff's request that the Company upload to Edgar copies of the seven agreements which were previously provided to the Staff for its consideration, we have attached copies of those agreements to this supplemental response for your files. If you require further information or have further comments, please feel free to call me at my direct number at (310) 889-2511 or you can reach me at my direct facsimile number (310) 496-1606. Sincerely, /s/ David T. Nguyen David T. Nguyen Treasurer and Controller Principal Financial Officer cc: John V. Winfield Michael G. Zybala Audit Committee -2- -----END PRIVACY-ENHANCED MESSAGE-----