COMBINED PENNY STOCK FUND INC
NSAR-B, EX-99.C1, 2000-11-30
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         AUDITOR'S REPORT ON INTERNAL CONTROL EX-99.C1


To the Board of Directors and Shareholders,
 Combined Penny Stock Fund, Inc.

In planning and  performing  our audit of the  financial  statements of Combined
Penny  Stock Fund,  Inc.  (the Fund) for the year ended  September  30, 2000 (on
which we have  issued our report  dated  October 19, 2000),  we  considered  its
internal control structure, including procedures 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  requirements  of Form
N-SAR, not to provide assurance on the internal control structure.

The management of the Fund is responsible  for  establishing  and maintaining an
internal control  structure.  In fulfilling this  responsibility,  estimates and
judgements  by  management  are  required to assess the  expected  benefits  and
related costs of internal control structure policies and procedures.  Two of the
objectives  of an internal  control  structure  are to provide  management  with
reasonable, but not absolute, assurance that assets are safeguarded against loss
from  unauthorized  use or  disposition  and that  transactions  are executed in
accordance  with  management's  authorization  and  recorded  properly to permit
preparation  of financial  statements  in  conformity  with  generally  accepted
accounting principles.

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

Our  consideration  of the  internal  control  structure  would not  necessarily
disclose all matters in the internal  control  structure  that might be material
weaknesses  under standards  established by the American  Institute of Certified
Public  Accountants.  A material  weakness is a condition in which the design or
operation of the specific internal control structure elements does not reduce to
a relatively  low level the risk that errors or  irregularities  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 the internal control structure,  including procedures for safeguarding
securities,  that we consider to be material  weaknesses  as defined above as of
September 30, 2000.

This report is intended solely for the information and use of management and the
Securities and Exchange Commission.

/s/Stockman Kast Ryan & Co., LLP

Stockman Kast Ryan & Company, LLP
Colorado Springs, Colorado
October 19, 2000



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