Subject: File No. S7-16-98 Comments

Date:    8/12/98 5:58 PM
     
     
As a CPA in industry, I find your proposed amendment to Rule 1029(e) to be 
completely out of line with the philosophy of accountants being able to make 
business related decisions and exercise independent judgement in accounting 
treatment.  Of course we will follow GAAP and SEC guidelines, but your 
proposed amendment will cause all CPA's to not push the envelope of 
opportunities within these frameworks.  These types of calls are not 
negligence related.  Any cases involving negligence, should be dealt with at 
the state level where the licenses are controlled, not at a national level 
or non-licensing agency such as yourself.
     
Sincerely
Dan Ramey, CPA
     
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Dan Ramey
Manager - KEI Operations Accounting
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