Date:    09/08/2000  8:43 AM

Subject: S7-13-00

Dear Chairman Levitt, Secretary Katz, and Commissioners Casey, Hunt, Jr., & 
Unger:
     
I wish to state my opposition to the scope of services rule prohibiting 
non-audit services to audit clients.  I believe the SEC should reexamine the 
conclusions of their own Panel on Audit effectiveness of the Public Oversight 
Board, which found no evidence that non-audit services have hurt audit quality. 
Even though the proposed rule is not intended to effect tax preparation 
services, this creates an undue burden for our clients who need tax consulting 
an planning advice which is more efficiently provided by the tax preparer. 
These services often extend well beyond the compliance of return preparation.
I believe the Proposal to restrict services offered by accounting firms that 
perform audit services is an unnecessary intervention by the government into a 
profession that continues to govern it self with high standards of independence.
Please reconsider and decline to implement this rule change.
     
Sincerely,
Julia C. Lackey, C.P.A.
Moss Adams LLP
Seattle, WA