Date:    09/19/2000  1:13 PM

Subject: File Number  S7-13-00

Dear Mr. Katz:
     
I have been recently informed of the proposed SEC plan to institute a rule that 
will limit the scope of CPA services.  I was informed by an article in the Utah 
Association of CPA's monthly newsletter.  The title of the article was "SEC 
Proposes Limiting Scope of CPA Services".  The article starts out by saying "The
SEC has proposed a rule change that would adversely affect accounting firms and 
companies."
     
I can not disagree more--it is time (long over-due) that the public accounting 
profession recognizes that the audit/attest function must be separated from the 
the performance of incompatible services.  Particularly when the other service 
requires or suggests that the CPA is an advocate in the service that he or she 
performs.
     
I have had a recent experience that clarified this problem in my eyes.  I was 
retained to be an expert witness on the valuation of a shareholder dispute which
involved the valuation of the company.  The company's "CPA/Auditor" was hired by
the other side to be their witness. As you may be aware, in litigation 
engagements, it is often assumed that the expert is an "advocate".  This raises 
very serious concerns over "independence" when the auditor is also acting as an 
advocate. 
     
I would be more than happy to explain the issues of the above case if you 
desire.
     
Best regards;
     
Bob Green
     
     
     
     
Robert L. Green, CPA, CVA, CFE
President
ValueNetex, Business Valuation Technology 
3191 S. Valley Street
Suite 205
Salt Lake City, UT 84109