August
15, 2007
William
H. Thompson
Branch
Chief
Division
of Corporation Finance
U.
S. Securities and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549
RE:
J. C. Penney Company, Inc.
Form
10-K for Fiscal Year Ended February 3, 2007
Filed
April 4, 2007
Form
10-Q for Fiscal Quarter Ended May 5, 2007
File
No. 1-15274
Dear
Mr. Thompson:
We
appreciate the Staff’s timely and thorough consideration of our responses to
your letter dated June 19, 2007 on the above-referenced filings for J. C. Penney
Company, Inc. (JCPenney). We received your follow up letter dated August 3,
2007
and have included our response to your additional comment below, with your
comment in bold preceding the related response.
Form
10-K for Fiscal Year Ended February 3, 2007
Note
20. Litigation, Other Contingencies and Guarantees, page
F-39
| 1. |
We
note your response to comment 4 in our letter dated June 19, 2007.
Please
confirm to us that you will disclose estimates of the amount of the
possible loss or range of loss or that such estimates cannot be made
when
there is a reasonable possibility that a loss exceeding amounts recognized
may have been incurred. Refer to paragraph 10 of SFAS
5.
|
-1-
Response
With
respect to the potential environmental liabilities disclosed in the second
and
third paragraphs of Note 20 on page F-39 of JCPenney’s Form 10-K for Fiscal Year
Ended February 3, 2007, we confirm that in future filings, in accordance with
paragraph 10 of SFAS 5, we will disclose estimates of the amount of possible
loss or range of loss or that such estimates cannot be made when there is a
reasonable possibility that a loss exceeding amounts recognized may have been
incurred.
Should
the Staff have any additional comments or need further information, please
contact either Sal Saggese, Chief Accountant, at (972) 431-2204 or ssaggese@jcpenney.com,
Salil Virkar, Senior Managing Counsel, at (972) 431-1211 or svirkar@jcpenney.com
or myself at (972) 431-1923 or rcavanau@jcpenney.com.
We
welcome the opportunity to work with the Staff in the future to continuously
improve the quality of our filings with the Commission.
Respectfully,
/s/
Robert B. Cavanaugh
Robert
B. Cavanaugh
Executive
Vice President and Chief Financial Officer
J.
C.
Penney Company, Inc.
-2-