Subject: File No. S7-16-98 [Rule 102(e)(1)(ii)

Date:    8/11/98 4:06 PM
     
     
August 10, 1998
Jonathan G. Katz
Securities and Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549-6009
     
Dear Mr. Katz:  Regarding the AICPAs request for opinions regarding Rule 
102(e)(1)(i), I believe that raising the bar for CPAs in public practice 
with SEC reporting clients is a prudent objective for the SEC in this 
time of massive CPA audit failures (Cendant, Physician's Computer 
Network, Inc., etc.).
     
Hence, even though I am a CPA, I am also an investor - an investor that 
got burned very badly on Physician's Computer Network, Inc.
     
I therefore applaud the SEC's efforts regarding how Rule 102(e)(1)(i) 
should be clarified such that a high standard of (not just reasonable) 
due care is taken in public company audits.

Respectfully submitted, 

Dr. John H. Nugent, CPA