The National Organization for Women, losing money, members and its fight to pass the Equal Rights Amendment, is sharply divided in a bitter and highly personal leadership fight between two former allies.

The contest pits former NOW president Eleanor Smeal against her handpicked successor, Judy Goldsmith, in a race both sides see as having important implications for the agenda and tactics of the women's movement.

But what began as a rather high-minded debate on the direction of the nation's largest feminist group erupted into an extraordinary skirmish last week over two subjects traditionally off-limits in NOW elections: the organization's finances and membership figures.

As 2,500 women prepared for NOW's annual convention in New Orleans next weekend, Smeal forces charged that NOW had lost its focus and more than 100,000 members during the three years of Goldsmith's presidency, fallen deeply into debt and abandoned the ERA as an issue. They also alleged that Goldsmith supporters on NOW's paid staff had packed a meeting of the organization's District of Columbia affiliate to elect delegates to the NOW convention, a charge denied by Goldsmith forces, which accused Smeal backers of waging "a witch hunt" that could damage the women's movement.

"Smeal partisans are using NOW's budget and membership figures as a political football. They've taken them entirely out of context," Goldsmith said. "It shows how desperate they have become."

Goldsmith escalated the conflict when, in an interview, she acknowledged that NOW was more than $1 million in debt, but said that $700,000 of that was part of a $1.1 million debt she inherited from a major ERA campaign waged during Smeal's presidency.

"You don't financially devastate an organization without paying a price for it. That is part of the price we're still paying," she said. "We have done extremely well in bringing the organization back from the vacuum we faced at the end of the ERA campaign."

Told of Goldsmith's remarks, Smeal said: "That's so shocking. That's not true. It was a donor loan. It's being forgiven as a gift from one anonymous donor that I got so we could go on television during the ERA campaign . . . . This was essentially a gift. It leaves me in state of shock that she'd talk to you about this."

Goldsmith, a former English professor from Wisconsin, is thought to have a slight lead in the race.

But Smeal supporters contend that the election is close. "If you're coming to New Orleans, wear your bulletproof vest," said Vicky Morean, a leading Smeal supporter from Virginia. "These elections ren't known for their niceties."

The two candidates see similar goals for the women's movement, but disagree sharply on the methods of achieving them.

"Ellie's answer to every problem is to raise hell; Judy's is to negotiate," said one longtime NOW supporter.

Behind their campaigns is a sharp division among NOW activists about how the women's movement should respond to the country's conservative drift. Should it work quietly behind the scenes, picking its public battles carefully, or should it confront conservatives at every crossroad?

Goldsmith, with a reputation as an effective coalition builder, is a believer in political realities. She boasts that under her leadership NOW has become a respected "multi-issue" organization with a firm financial base.

Smeal, 45, a former Pittsburgh housewife, is a charismatic ideologue whom her backers consider a visionary. She supports a politics of confrontation.

Goldsmith was elected with Smeal's support in a 1982 race presenting some of the same issues as the current one. Running as a political pragmatist, she defeated Sonia Johnson, who had gained fame for being banished from the Mormon church for her involvement in NOW, but was considered "too radical" by many NOW stalwarts.

Goldsmith, 46, led NOW firmly into the Democratic Party last year, endorsing Walter F. Mondale early and claiming major credit for his selection of Geraldine A. Ferraro as his running mate.

Smeal and most of her followers supported these moves, but they charge that NOW has become "an arm of the Democratic Party," lost its militant zeal and is in danger of becoming little more than a Washington bureaucracy.

Smeal proposes that NOW sponsor a mass march on Washington in support of legalized abortion, a major organizing effort on college campuses and an emergency campaign to pass the Civil Rights Restoration Act of 1985. She says she would also like to revive the ERA issue.

Smeal says these and other efforts would lead to "growth of NOW's membership, finances, visibility and overall activism."

NOW's finances and exact membership have long been a closely guarded secret. When Smeal left office in late 1982, she said NOW had 220,000 members and a $13 million budget. She boasted at the time that NOW would have a million members by the 1984 presidential election. NOW's current budget is $5.4 million.

Asked the size of NOW's membership, Goldsmith last week said, "Comfortably, a quarter million." But an aide later said NOW has 166,000 members and 68,900 active contributors, compared with 181,000 members and 41,500 contributors in 1982 when Goldsmith took office.

The only other public source for NOW's membership are circulation figures published once a year in the National NOW Times. In October 1982, the newspaper claimed a circulation of 290,000. By December 1984, the last time it published a figure, that number had dropped to 178,000.

Goldsmith said circulation figures were "bloated" during the Smeal years and that the newspaper is now sent only to paid members.

During five years as president, Smeal made a visible and controversial campaign for the ERA's ratification the cornerstone of the organization. The campaign failed, but NOW's membership grew dramatically from 60,000 in 1977.

"The ERA is a wonderful organizing tool and conscience-raiser," Smeal said in an interview. "We didn't get it, but we got other things as we went along. It spread feminism and legislation in its wake."

ERA campaigns, she said, have always raised more money for NOW and recruited more members through direct-mail solicitations than any other issue. "To me, you've got to make a stand and fight, but it also makes good dollars and cents," she added. "It's not a loser."

Goldsmith continued to use the ERA as a fund-raising tool in a highly successful direct-mail campaign in 1984, but she dropped it this year, according to Roger Craver, who heads a firm that has long raised the bulk of NOW's finances. Faced with a $250,000 mailing debt, Goldsmith cut back prospecting for new members by 10 percent, Craver said.

"I stopped using the ERA because I wasn't comfortable raising money on an issue that can't be legitimately be moved," Goldsmith said. "It would be irresponsible and immoral. We aren't interested in any more exercises in futility."