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Research the case of Ultramares Corporation v. Touche, 174 N.E. 441 (1932). This case addresses an accountants liability to third parties.  There are three theories of accountants liability that you will need to know for the CPA exam. The first is the Ultramares Rule (also known as the New York Rule). What are the other two? Which rule is followed by most states with respect to accountants liability to third parties? 

Apply the other theories of accountants liability to the fact pattern in Ultramares. Would the court have ruled the same in the other two theories? Would the accountant be found liable under the other two theories of accountants liabilities to third parties? Why or why not