Date:    09/06/2000  2:38 PM

Subject: non-audit service restriction s7-13-00

Dear Mr. Levitt,
     
I am writing to you regarding the restrictions currently proposed that will 
jeopardize my ability to continue my practice.  For eighteen years I have 
practiced in public accounting, providing a valuable service to my clients.
In addition to traditional auditing, I have performed many value added services 
that were greatly appreciated.  
     I believe the proposed rule changes will have negative impacts such as:
     
Reduce the pool of qualified business advisors to non-auditors 
Eliminate positive working relationships among affiliates 
Force a drastic increase in audit costs
Impede recruitment into the profession 
Prohibit representation in front of the IRS 
Set a precedent for other regulatory agencies.
     
I request that you focus on the conclusion of the Panel on Audit effectiveness 
of the POB that "both the profession and the quality of audits are fundamentally
sound".  Do not restructure a profession that has given investors reliable, 
independent data they need. Please stop the scope of services rule before the 
public's best interests are jeopardized.
     
Frank Kaufman, CPA
     
Frank Kaufman
Moss Adams LLP

FrankK@MossAdams.com