UNITED STATES OF AMERICA
                                     before the
                          SECURITIES AND EXCHANGE COMMISSION


          INVESTMENT ADVISERS ACT OF 1940
          Rel. No.  1773 / November 2, 1998

          Admin. Proc. File No. 3-9105

           ----------------------------------
                   In the Matter of         |
                                            |
                  IRA WILLIAM SCOTT         |
           ----------------------------------

          ORDER DENYING REQUEST FOR RECONSIDERATION

          On September 15, 1998, we issued an opinion affirming the
          decision of an administrative law judge to bar Ira William Scott
          from associating with an investment adviser based on Scott's
          conviction, under Indiana law, of thirteen felony offenses, [1]
          and in consideration of the public interest. [2]  Scott now
          requests that we reconsider our findings and conclusions.

          Scott challenges "the validity of the factual background of [his]
          criminal conviction" that is presented in the opinion, which he
          claims is "grossly outside of the trial record," [3] and which he
          suggests is the work of "a conspiracy of unknown persons."  While
          Scott claims that "[t]here are numerous instances of false
          information being supplied to the Commission" in this case, he
          supports his claim with only a single example.  He asserts that
          our finding to the effect that "[a]n investigation conducted by
          [a long-distance telephone] carrier revealed that Scott possessed
          117 stolen access codes . . ." conflicts with the criminal trial
          record.  That finding, however, was based on a decision of the
          Court of Appeals of Indiana, which held that, "[a]fter an
          investigation by Sprint, it was discovered that Scott possessed
          117 stolen access codes . . . ." [4]  This Indiana appellate
          decision became final when Scott's petition to the Indiana
          Supreme Court was denied.  As a result, Scott is collaterally
          estopped from attacking the findings of the Indiana appellate
          court. [5]  Under the circumstances, we see no reason to
          reconsider our decision.

          Accordingly, IT IS ORDERED that the petition for reconsideration
          filed by Ira William Scott be, and it hereby is, denied.

          By the Commission.





          Jonathan G. Katz
          Secretary

          **FOOTNOTES**

[1]: Scott was convicted of four counts of theft, three counts of sale of a
security by an unregistered agent, three counts of sale of an unregistered
security, and three counts of fraud in connection with the sale of a
security.

[2]: Ira William Scott, Investment Advisers Act Rel. No. 1752 (September
15, 1998), __ SEC Docket __.

[3]: Although Scott refers to and quotes from what he claims is the record
from his criminal trial, that record was not introduced by either party
into the record in these proceedings.

[4]: Ira Scott v. State Of Indiana, No. 64A03-9303-CR-00098 (Ind. Ct. App.
Sept. 29, 1994) (affirming Scott's criminal conviction).

[5]: As we held in our prior opinion, "`[a] criminal conviction cannot be
collaterally attacked in an administrative proceeding.  This prohibition
extends to issues relating to the validity of the conviction, including the
credibility of the evidence presented at trial and any defenses to the
criminal charge.'"  Ira William Scott, __ SEC Docket at __ (citations
omitted).