EX-99.77B ACCT LTTR

Report of Independent Accountants


To the Board of Directors and Shareholders of
Columbia Special Fund, Inc.


In planning and performing our audit of the financial statements of
Columbia Special Fund, Inc. (the Fund) for the year ended
December 31, 2001, we considered its internal control, including
control activities for safeguarding securities, in order to determine
our auditing procedures for the purpose of expressing our opinion
on the financial statements and to comply with the requirements of
Form N-SAR, not to provide assurance on internal control.

The management of the Fund is responsible for establishing and
maintaining internal control.  In fulfilling this responsibility,
estimates and judgments by management are required to assess the
expected benefits and related costs of controls.  Generally, controls
that are relevant to an audit pertain to the entity's objective of
preparing financial statements for external purposes that are fairly
presented in conformity with accounting principles generally
accepted in the United States of America.  Those controls include
the safeguarding of assets against unauthorized acquisition, use or
disposition.

Because of inherent limitations in internal control, errors or fraud
may occur and not be detected.  Also, projection of any evaluation
of internal control to future periods is subject to the risk that
controls may become inadequate because of changes in conditions
or that the effectiveness of their design and operation may
deteriorate.

Our consideration of internal control would not necessarily
disclose all matters in internal control that might be material
weaknesses under standards established by the American Institute
of Certified of Public Accountants.  A material weakness is a
condition in which the design or operation of one or more of the
internal control components does not reduce to a relatively low
level the risk that misstatements caused by error or fraud in
amounts that would be material in relation to the financial
statements being audited may occur and not be detected within a
timely period by employees in the normal course of performing
their assigned functions.  However, we noted no matters involving
internal control and its operation, including controls for
safeguarding securities, that we consider to be material weaknesses
as defined above as of December 31, 2001.

This report is intended solely for the information and use of the
Board of Directors, management and the Securities and Exchange
Commission and is not intended to be and should not be used by
anyone other than these specified parties.

PricewaterhouseCoopers LLP

February 8, 2002

EX-99.77O RULE 10F-3

EXHIBIT 77.O

77.O	TRANSACTIONS EFFECTED PURSUANT TO RULE 10F-3

Columbia Special Fund, Inc.:

Qualifying transactions are listed below.  On a
quarterly basis, the Registrant's Board of Directors
receives a Form 10F-3 containing information that
enables them to determine that all purchases made
during the quarter were effected in compliance with
the Registrant's 10F-3 procedures.


1)	Issuer:            Instinet Group, Inc.
	Date of Purchase:  5/17/2001
	Underwriter from whom Purchased:
                         First Boston (Credit Suisse)
	Affiliated Underwriters:
       Robertson Stephens
	Other Members of Syndicate:
	 JP Morgan/Chase Securities
	                   Deutsche Banc Alex Brown
                         Bear, Stearns & Co.
                         Merrill Lynch & Co.
                         Thomas Weisel Partners LLC
                         Salomon Smith Barney
                         WR Hambrecht & Co.
                         Banc of America Securities
                         William Blair & Co. LLC
                         CIBC World Markets Corp.
                         Dain Rauscher, Inc.
                         First Union Securities
                         Prudential Securities
                         SG Cowen Securities
                         U.S. Bancorp Piper Jaffray
	Aggregate dollar amount of purchase:
					$435,000
	Aggregate dollar amount of offering:
					$464,000,000
	Purchase price (net of fees and expenses):

	$13.98 per share
	Date offering commenced:
					5/17/2001
	Commission:			$0.52













2)	Issuer:             Instinet Group, Inc.
	Date of Purchase:   6/27/2001
	Underwriter from whom Purchased:
                          U.S. Bancorp Piper Jaffray
	Affiliated Underwriters:
        Robertson Stephens
	Other Members of Syndicate:
	                    JP Morgan/Chase Securities
	                    Banc of America Securities
                            Hambrecht & Quist
      Aggregate dollar amount of purchase:
			        $5,651,440.00
	Aggregate dollar amount of offering:
				  $114,800,000.00
	Purchase price (net of fees and expenses):
	                         $15.86 per share
	Date offering commenced:
				  6/27/2001
	Commission:	        $0.54