CALDWELL & ORKIN FUNDS INC
NSAR-B, EX-99.77B, 2000-06-27
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               REPORT OF INDEPENDENT CERTIFIED PUBLIC ACCOUNTANTS
                          ON INTERNAL CONTROL STRUCTURE



Board of Directors and Shareholders
Caldwell & Orkin Funds, Inc.
Norcross, Georgia


In planning and performing  our audit of the financial  statements of Caldwell &
Orkin Market  Opportunity  Fund for the year ended April 30, 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 the
requirements  of Form N-SAR,  not to provide  assurance on the internal  control
structure.

The management of Caldwell & Orkin Funds,  Inc. is responsible for  establishing
and   maintaining   an  internal   control   structure.   In   fulfilling   this
responsibility, estimates and judgments 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
April 30, 2000.

This report is intended solely for the information and use of management and the
Securities  and  Exchange  Commission,  and  should  not be used  for any  other
purpose.



                                                            TAIT, WELLER & BAKER

Philadelphia, Pennsylvania
June 21, 2000



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