CAPPIELLO RUSHMORE TRUST
40-17F2, 1999-06-04
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Cappiello-Rushmore Trust
4922 Fairmont Avenue
Bethesda, Maryland   20814


To the Board of Trustees of Cappiello-Rushmore Trust:

We are the auditors of the Cappiello-Rushmore Trust (the Trust), a series
investment company comprised of four portfolios, Utility Income, Growth,
Emerging Growth and Gold portfolios (the Portfolios).  Rushmore Trust
and Savings, FSB (Rushmore Trust), a related entity, is custodian of all of
the Trust's portfolios and the Trust is therefore subject to the provisions of
Rule 17f-2 under the Investment Company Act of 1940.  Accordingly, we
have accounted for the Portfolios' investment securities held by Rushmore
Trust as of the close of business on June 30, 1998.  It is understood that
this report is solely for the use of management and for the information of
the Securities and Exchange Commission and should not be used for any
other purpose.

Rushmore Trust, in addition to acting as custodian for the Portfolios, is
custodian for other customers.  Agents of Rushmore Trust hold, or account
for by book entry, securities that are the responsibility of Rushmore Trust
through custodial or trust agreements.  Securities held by agents of
Rushmore Trust, while identified by such agents as being deposited by
Rushmore Trust, cannot be identified by such agents as to the specific
customers of Rushmore Trust who have securities included in such
deposits.

Rushmore Trust confirmed to us that the portfolio securities owned by the
Trust on June 30, 1998 were held for the account of Rushmore Trust by
Mellon Bank, N.A. (Mellon), as agent for Rushmore Trust.  We obtained
confirmation from Mellon of the securities held for the account of
Rushmore Trust as of June 30, 1998.  We reviewed Rushmore Trust's
reconciliation of Mellon's confirmation to Rushmore Trust's internal records,
identifying securities held by Mellon as a part of Rushmore Trust's aggregate
security position with Mellon.  We also reviewed Rushmore Trust's records
that show the owners of the securities held by Mellon for the account of the
Rushmore Trust at June 30, 1998.  We determined that these securities,
identified by such records as the property of the Trust's Portfolios, were in
agreement with the Trust's records of securities owned at June 30, 1998.  In
addition, brokers confirmed to us the purchases and sales outstanding at June
30, 1998, which were in agreement with the Portfolios' records.  We also
agreed an analysis of portfolio transactions recorded subsequent to June 29,
1998, the date of our most recent examination of the Trust's securities
required under Rule 17f-2, in the investment accounts to supporting records
and verified a sample of portfolio security transactions to supporting records
and documentation.

Because the above procedures were not sufficient to constitute an audit
conducted in accordance with generally accepted auditing standards, we do
not express an opinion on the investment accounts referred to above as of
the dates indicated.  In connection with the procedures referred to above, no
matters came to our attention that caused us to believe that the specified
accounts should be adjusted.  Had we performed additional procedures or
had we conducted an audit of the financial statements of the Trust in
accordance with generally accepted auditing standards, matters might have
come to our attention that would have been reported to you.  This report
relates only to the investments specified above and does not extend to the
financial statements of the Trust, taken as a whole for any date or period.

Deloitte & Touche LLP
Washington, DC
August 7, 1998




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