Subject: File No. S7-04-00

Date:    05/13/2000 5:40 PM
     
     
Dear Mr Katz,
     
I have a attached a paper that details unpublished research about the 
use of verbal probability expressions (remote, probable, virtually 
certain etc) in accounting standards.  As the respondents were 55 
experienced auditors employed in countries that have substantially 
adopted IAS's (Hong Kong, Malaysia and Singapore) I contend that the 
reported findings may be of interest to the SEC.  In particular the 
research reports findings about the consistency (or otherwise) in the 
interpretation of verbal probability expressions between three different 
reporting jurisdictions.
     
Regards
     
Mark Shying
Senior Lecturer
School of Accounting and Finance
Footscray Park Campus
Victoria University
MMC
Melbourne 8001
Australia