November 9, 1999

Mr. Richard Mascolo
Chief, Regulatory Division
Bureau of Alcohol, Tobacco and Firearms
 Department of the Treasury
Washington, DC   20226

Re:       Pre-published regulation - Increase on Tobacco
Products and Cigarette Papers and Tubes
     Amendments to 27 CFR Parts 270, 275, 290, 295, 296.


Dear Mr. Mascolo:

I have reviewed the Bureau of Alcohol, Tobacco & Firearms' draft
copy of a "final regulation" entitled:Increase on Tobacco
Products and Cigarette Papers and Tubes.    I have no direct
comment on the substance of this pre-published regulation that
amends the tax rates on the above products to reflect the
statutory change made by Congress.  I do have a procedural
comment.  Your letter was forwarded to me by the Administrator
of the Small Business Administration.  Under I.R.C.  7805(f)
the regulation should be sent to "the Chief Counsel for Advocacy
of the Small Business Administration for comment on the impact
of such regulation on small business."  If it is sent to the
Administrator instead, then it generally takes some time to get
here if at all and we may miss an opportunity to comment.  .

Thank you for sending the pre-published regulation.  Please do
not hesitate to call on me or Russell Orban (205-6946 or
russell.orban@sba.gov  if we can be of further assistance.

With respect, I remain

Sincerely,



Jere W. Glover
Chief Counsel for Advocacy