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<SEC-DOCUMENT>0000891092-08-002400.txt : 20080619
<SEC-HEADER>0000891092-08-002400.hdr.sgml : 20080619
<ACCEPTANCE-DATETIME>20080502144440
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000891092-08-002400
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20080502

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			TAITRON COMPONENTS INC
		CENTRAL INDEX KEY:			0000942126
		STANDARD INDUSTRIAL CLASSIFICATION:	WHOLESALE-ELECTRONIC PARTS & EQUIPMENT, NEC [5065]
		IRS NUMBER:				954249240
		STATE OF INCORPORATION:			CA
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		28040 WEST HARRISON PARKWAY
		CITY:			VALENCIA
		STATE:			CA
		ZIP:			91355
		BUSINESS PHONE:		(661) 257-6060

	MAIL ADDRESS:	
		STREET 1:		28040 WEST HARRISON PARKWAY
		CITY:			VALENCIA
		STATE:			CA
		ZIP:			91355
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
[Logo] TAITRON                                      28040 West Harrison Parkway
components incorporated                             Valencia, CA  91355
                                                    Tel  (661) 257-6060
                                                    Fax (661) 294-1108

May 2, 2008

Mr. Kevin L. Vaughn, Accounting Branch Chief
U.S. Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W., Mail Stop 0510
Washington, DC 20549-0510

Re:  Taitron Components Inc.
     Form 10-KSB for the year ended December 31, 2007
     Filed March 31, 2008
     File No. 000-25844

Dear Mr. Vaughn:

      This letter sets forth the  responses of Taitron  Components  Incorporated
(the "Company", "we" or "our") to the comments of the staff of the U.S. Securiti
es and Exchange  Commission  (the  "Commission")  contained in your letter dated
April 21, 2008.  Our  responses  set forth below  correspond  to the comments as
numbered in the staff's letter.

Form 10-K for the Year Ended December 31, 2007

Consolidated Balance Sheet, page 19

1.    We note your significant  inventory balance at December 31, 2007, which is
      net of approximately $2.5 million of inventory reserves. We also note your
      disclosures  on page  13 that  "if  all or a  substantial  portion  of the
      inventory was required to be immediately  liquidated...we  may not realize
      the full carrying value of [your] reported  inventories." Finally, we note
      the  disclosure  in  Note 9 on  page 30  that  in  addition  to the  large
      inventory balance,  you also have inventory  purchase  commitments of $1.5
      million  as of  December  31,  2007.  As such,  we note that the  combined
      current  inventory  balance and  current  inventory  purchase  commitments
      appears to represent  approximately three years of inventory on hand as of
      December 31, 2007. Please address the following:

      o     Please  explain  to us  why  you  believe  that  your  inventory  is
            appropriately  valued at the lower of cost or market as of  December
            31,  2007.  In  light of the fact  that you have  over two  years of
            inventory on hand, please include specific discussion of the risk of
            obsolescence of your inventory.


                                  Page 1 of 4
<PAGE>

      o     Revise your discussion under Critical Accounting Policies in MD&A in
            future  filings to  describe  your  inventory  reserve  analysis  in
            greater detail. Discuss the inventory balance in relation to current
            sales  trends.  Also discuss your  judgments  regarding  the risk of
            obsolescence  in  connection  with  the  large  inventory   balance.
            Finally,  please note that your inventory reserve  discussion should
            also consider any inventory purchase commitments you may have. Refer
            to SEC Release 33-8350 for additional guidance regarding  discussion
            of Critical Accounting Estimates.

Company Response:

We advise the Commission  that our inventories  consist  principally of discrete
semiconductors,   optoelectronic   devices  and  passive   components  that  are
distributed  to a wide  array  of  electronic  distributors  and  manufacturers.
Generally,  our  inventories  are  mature  products  that  are  not  subject  to
obsolescence from  technological  advancements.  However,  management  considers
future  price  deflation  to be a  potential  risk in regards  to our  inventory
valuation.  Therefore,  each  quarter,  we perform a  detailed  lower of cost or
market (LCM)  analysis.  The  application  of LCM is our means of  attempting to
measure the sales  margin and  inventory  recoverability  from  changing  market
prices and  recognize  the  effects  in the period in which it occurs.  This LCM
analysis  is  applied  to our  inventory  on a  brand-by-brand  basis,  covering
approximately  145 distinctly  separate brand  categories.  We also  selectively
review  our high  value  inventory  items  on a  part-by-part  basis  for a more
detailed  LCM  analysis.  This  LCM  process  gathers  available  data,  such as
historical sales, purchasing history and replacement cost information,  for each
brand and determines the market value (market value equaling  replacement  cost,
but not exceeding the net realizable  value, nor below net realizable value less
a normal  25% profit  margin)  and then  compares  this to our cost  basis.  Our
replacement cost information comes from supplier inquiry or current price lists.
Any inventory valuation  adjustment resulting from our LCM analysis is reflected
in the income  statement in cost of goods sold in the period in which it occurs.
Also,  we  regularly  apply  our  reserves  to  write-down  the  cost  basis  of
specifically  identified  inventories,  rather than maintain  higher  grossed up
costs and the related higher reserve levels.

Our purchase  commitment of $1,500,000 at year-end relates to scheduled delivery
dates  forecasted  over  120  days,  as  we  generally   experience  60-90  days
manufacturing  lead times from suppliers,  plus 30 days sea shipping lead times.
The reason for this  commitment  level is  threefold:  (1) to meet our scheduled
sales order  backlog,  (2) to increase  our  component  inventory  portfolio  by
offering a wider breadth of product  choices and (3) to support our  engineering
and  contract  manufacturing  services.  We are  generally  able to cancel these
purchase  commitments  within  30-60  days  advance  notice,  depending  on  the
supplier's  terms and conditions.  Upon receipt into inventory,  these purchases
are reviewed along with our LCM analysis, discussed above.

Our  business  strategy  is  to  extend  our  role  from  electronic   component
fulfillment to the additional  role of engineering  and turn-key  services.  Our
initial  results from these  services  have shown the ability to use some of our
slower moving inventory to supply the components for these  multi-year  turn-key
projects.  As a result, we believe these services will help reduce our inventory
levels over time.


                                  Page 2 of 4
<PAGE>

Based  on  the  aforementioned  information,  we  believe  our  inventories  and
outstanding  purchase  commitments  are  recoverable  in the ordinary  course of
business;  and as such,  we believe the December 31, 2007  inventory  reserve is
adequately stated in its consolidated financial statements.

Further,  we will revise our discussions under Critical  Accounting  Policies in
MD&A in future  filings to describe our  inventory  reserve  analysis in greater
detail,  including  its  relation to our  purchase  commitments,  our  inventory
balance in relation to current sales trends and our judgments regarding the risk
of obsolescence in connection with our inventory.

Consolidated Statement of Cash Flows, page 22

2.    We note that the effect of  exchange  rates on cash of $37,000 and $24,000
      for 2006 and  2007,  respectively,  are the same as the  foreign  currency
      translations  on your  consolidated  statements of  shareholders'  equity.
      Please tell us whether you prepared the  statement of cash flows using the
      exchange rates in effect at the time of the cash flows in accordance  with
      paragraph 25 of SFAS 95. Revise as necessary in future filings.


Company Response:

We advise the Commission that appropriately  weighted average exchange rates for
the period were used to prepare our  statement of cash flows,  as the result was
substantially the same as if we used the rates in effect at the time of the cash
flows and the effect of exchange  rate changes on cash  balances held in foreign
currencies  as a separate part of the  reconciliation  of the change in cash and
cash equivalents during the period.

Notes to Consolidated Financial Statements, page 23

3.    We note from page 22 that you invested  $148,000 in joint ventures  during
      fiscal 2007.  Please revise your notes in future  filings to disclose your
      material  investments.  Disclose  the  nature of these  investments,  your
      percentage  ownership of each investment,  and your accounting  policy for
      any investments.


Company Response:

We advise the Commission that future filings will disclose material investments,
including  the nature of these  investments,  our  percentage  ownership of each
investment, and our accounting policy for any investments.

Note 7. Stock Options, page 29

4.    We note from your  disclosures that you utilize the  Black-Scholes  option
      pricing  model to determine the fair value of your stock  options.  Please
      revise  this note in future  filings to  explain  how you  determined  the
      assumptions  utilized  in these  models  including  volatility,  risk free
      interest  rate,  expected  life,  etc. Refer to the guidance in paragraphs
      A240-242 of SFAS 123(R) and SAB Topic 14.


Company Response:

We advise the  Commission  that this note in future  filings will explain how we
determined these  assumptions,  including  volatility,  risk free interest rate,
expected life, etc.


                                  Page 3 of 4
<PAGE>

Item 8A. Controls and Procedures, page 31

5.    We note that you provided  management's  annual report on internal control
      over financial  reporting as of December 31, 2007 pursuant to Item 308T of
      Regulation  S-K.  However,  we note that you did not  provide a  statement
      identifying the framework used by management to evaluate the effectiveness
      of your  internal  control over  financial  reporting.  Please tell us and
      revise  future  filings to clearly  disclose  the  framework  utilized  by
      management to evaluate your  effectiveness  of your internal  control over
      financial reporting. Refer to Item 308T9(a)(2) of Regulation S-K.


Company Response:

We  advise  the  Commission  that in making  our  internal  control  assessment,
management   used  the  criteria  set  forth  by  the  Committee  of  Sponsoring
Organizations  of the  Treadway  Commission  in Internal  Control --  Integrated
Framework  (COSO).  Further,  our future  filings will  disclose  the  framework
utilized by management  to evaluate the  effectiveness  of our internal  control
over financial reporting.


Exhibit 31.1

6.    We note that your  certifications  filed  pursuant  to  Exchange  Act Rule
      13a-14(a)  are not in the exact  form  prescribed  by Item  601(b)(31)  of
      Regulation   S-B.   Specifically,   we  note   that  the  Rule   13a-14(a)
      certifications  included with this filing omit (i) paragraph 4(b) and (ii)
      the portion of the introductory language in paragraph 4 that refers to the
      responsibility of the certifying officers for establishing and maintaining
      the registrant's  internal control over financial reporting.  Please amend
      your filing to include  revised  certifications  that conform to the exact
      wording required by Item 601(b)(31) of Regulation S-B. Please note that we
      would not object if you  elected  to file an  abbreviated  amendment  that
      includes the cover page, an  explanatory  note,  the signature  page,  and
      paragraphs 1, 2, 4 and 5 of the certifications.


Company Response:

We advise the Commission that our filing will be amended as recommended.

Lastly, per your request, we acknowledge the following:

o     the company is responsible for the adequacy and accuracy of the disclosure
      in the filing;

o     staff  comments or changes to disclosure in response to staff  comments do
      not  foreclose the  Commission  from taking any action with respect to the
      filing; and

o     the company may not assert staff  comments as a defense in any  proceeding
      initiated by the  Commission  or any person  under the federal  securities
      laws of the United States.

      We remain hopeful that the foregoing responds adequately to your comments.
If you have any questions or need further clarification, please call me at (661)
257-6060, extension 300.

      Sincerely,
      /s/ Stewart Wang
      -----------------
      Stewart Wang
      Chief Executive Officer and Chief Financial Officer


                                  Page 4 of 4
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