Subject: File No. s7-16-98
Author:  Jeff Pruett  
Date:    8/12/98 10:06 AM
     
     
I wish to take advantage of the opportunity to comment on the proposed 
amendment to rule 102(e).  I find myself compelled to disagree with the 
commission's proposed language and to agree with the proposed language 
by the AICPA.  As a CPA in Industry and the "Chief Accounting Officer" 
for my company I am concerned with the potential for a liberal 
application of your proposed amendment.  I find the arguments presented 
by the AICPA in their letter dated August 1998 as very compelling and in 
my opinion appropriate for the intended purpose.  I urge you to consider 
them carefully and I think you will agree that they meet the objectives 
of the Comission without the negative implications of the proposed 
wording.  Respectively yours,  Jeffrey W. Pruett CPA