September 14, 2000

Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Dear Mr. Katz:

Atkinson & Co., Ltd., a local CPA firm in Albuquerque, New Mexico has had an opportunity to review the Securities and Exchange Commission, Revision of the Commission's Auditor Independence Requirements; Proposed Rule, 65 Fed. Reg 43, 148(2000). There are certainly parts of the proposed rulemaking that would alleviate certain overly burdensome restrictions on investments and employment relationships involving audit clients and the families of certain audit firm personnel, however, the most significant impact of the proposed rule would dramatically curtail the ability of CPA firms such as ours to provide services other than audit and certain tax services to our customers. As a result, we would ask that you reconsider the scope of services rule for the following reasons:

We believe that the proposed scope of services rule will more than likely have the perverse effect of undermining auditor independence by making audit firms overly or exclusively dependent on auditing fees, which would certainly be contrary to the public interest. The CPA profession has successfully given investors the reliable, independent data they need for the past century. Allow us to continue to protect the public interest by not going forward with your proposed scope of services rule.


Atkinson & Co., Ltd.
Barbara A. Lewis
Shareholder in Charge of Audit