Subject: S7-17-98
Author:  Lou Miller 
Date:    7/29/98 8:56 PM
     
     
                                        July 29, 1998
     
     
Mr. Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission 
450 Fifth Street, N.W.
Washington, D.C. 20549
     
     
                                Re:  File No. S7-17-98
     
     
Dear Mr. Katz:
     
In Release No. 33-7549, "Segment Reporting," issued June 25, 1998, the 
Commission has proposed certain technical amendments to conform its 
reporting requirements with Statement of Financial Accounting Standards No. 
131, which will soon be effective for all publicly-owned companies.
     
The proposed modification of Section 501 of the Codification of Financial 
Reporting Policies contains an example which states that "Segment I sales 
increased 22% in Year 3 over the Year 2 period. The increase included the 
effect of the acquisition of Corporation T. Excluding this acquisition, 
sales would have increased by 16% over Year 2."
     
As a practical matter, a registrant cannot determine what the amount of its 
sales "would have been" sans acquisitions. If the acquisition of Corporation 
T had not been consummated, Corporation X might have been acquired or, 
alternatively, a different sales and marketing strategy might have been 
employed.
     
In addition, I would suggest that Article 10, Interim Financial Statements, 
be amended to require disclosures pursuant to paragraph 33 of SFAS No. 131. 
Paragraph 33 could be interpreted as requiring registrants to report interim 
segment information only if such is disseminated to stockholders.
     
     
Very truly yours,
     
Louis K. Miller
Wynnewood, Pennsylvania