Date:    06/29/2000  8:12 AM

Subject: File No. S7-09-00

To Whom it may Concern:
     
I am issuing what I believe to be a very important comment governing after-tax 
returns to avoid misleading the public.  
     
1) I'm in favor of requiring mutual fund firms to report after-tax returns, but
     
2) I also believe that, in addition to the proposed methodology, a liquidation 
analysis should be used.  Returns should be reported assuming a complete 
liquidation of the fund at the end of the period presented.
     
Why?  Because firms which are adding assets through growth will, naturally, look
better on an after-tax basis to those with declining assets.  Built in 
unrealized gains represent a natural "liability" to mutual fund shareholders--if
the fund's assets were to decline significantly, those unrealized gains would 
have to be realized.
     
This analysis will also be a fair compromise between indexed and active mutual 
funds.
     
INCLUDE THIS IN THE FINAL PROPOSAL.
     
Sincerely,
     
William C. Sonneborn