0000077543-18-000082.txt : 20181109 0000077543-18-000082.hdr.sgml : 20181109 20181009184439 ACCESSION NUMBER: 0000077543-18-000082 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20181009 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TUTOR PERINI CORP CENTRAL INDEX KEY: 0000077543 STANDARD INDUSTRIAL CLASSIFICATION: GENERAL BUILDING CONTRACTORS - NONRESIDENTIAL BUILDINGS [1540] IRS NUMBER: 041717070 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 15901 OLDEN STREET CITY: SYLMAR STATE: CA ZIP: 91342 BUSINESS PHONE: 818-362-8391 MAIL ADDRESS: STREET 1: 15901 OLDEN STREET CITY: SYLMAR STATE: CA ZIP: 91342 FORMER COMPANY: FORMER CONFORMED NAME: TUTOR PERINI Corp DATE OF NAME CHANGE: 20090529 FORMER COMPANY: FORMER CONFORMED NAME: PERINI CORP DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm Response to SEC Comment Letter - 2018-10-5

Tutor Perini Corporation

15901 Olden Street

Sylmar, CA 91342

Tel: 818/362-8391 Fax: 818/367-5379

October 9, 2018



VIA EDGAR



Mr. John Cash

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549





 

Re:

Tutor Perini Corporation



Form 10-K for the Fiscal Year Ended December 31, 2017



Filed February 27, 2018



File No. 001-06314





Dear Mr. Cash:



Set forth below is the response of Tutor Perini Corporation (the “Company”) to the letter dated October 5, 2018 providing further comment of the staff (the “Staff”) of the Securities and Exchange Commission on the Company’s Annual Report on Form 10-K for the year ended December 31, 2017.



For ease of reference, the Staff’s comment is reproduced below in bold font and followed by the Company’s response thereto.





Form 10-K for the Year Ended December 31, 2017



Critical Accounting Policies – Recoverability of Goodwill, page 28



1.

We note your response to our prior comment two. Please expand your disclosure in future annual filings:



• To address how you consider market capitalization as part of your annual goodwill impairment test, similar to the information you provided in your response letter; and

• To state, if true, that the fair values of your reporting units substantially exceed their respective carrying values.



 

 

Mr. John Cash

United States Securities and Exchange Commission

Page 2 of 2





Response:



In future annual filings, the Company will address how it considers market capitalization as part of its annual goodwill impairment test, similar to the information provided in the Company’s response letter dated September 28, 2018. In addition, the Company will state, if true, that the fair values of its reporting units substantially exceed their respective carrying values.







 





Please feel free to contact me at 818/362-8391 if you have any questions.





Sincerely,







/s/ Gary G. Smalley

Gary G. Smalley

Executive Vice President and Chief Financial Officer