April 17, 2000


Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-1004

ATTN:  Ms. Patsy W. Mengiste, Document Control - EDGAR

RE:      Form N-14 Pre-Effective Amendment No. 1 for -
                  AXP New Dimensions Fund, Inc. (File No. 333-32322)


Dear Ms. Mengiste:


Pursuant to Rule 461,  American Express  Financial  Advisors Inc., the Principal
Underwriter,   respectively   requests   that   the   effective   date   of  the
above-mentioned  Registration Statement be accelerated and declared effective on
April 17, 2000 or as soon as practicable thereafter.


Sincerely,

American Express Financial Advisors Inc.
(Principal Underwriter)



By: /s/  William A. Stoltzmann
         William A. Stoltzmann
         Vice President and Assistant General Counsel