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(n60) AICPA PROFESSIONAL STANDARDS, Code of Professional Ethics ET Section 51.04 (Am. Inst. of Certified Pub. Accountants (CCH) 1984).

(n61) United States v. Arthur Young & Co., 465 U.S. 805, 817-18 (1984).

(n62) 223 Cal. Rptr. 218, 224-25 (Cal. Ct. App. 1986) overruled by Bily v. Arthur Young & Co., 834 P.2d 745 (Cal. 1992). See supra note 22.

(n63) 223 Cal. Rptr. at 225-27.

(n64) PREVITS & MERINO, supra note 30, at 316. The use of footnotes to the statements would be insufficient to avoid this presumption.

(n65) Id. at 316-17.

(n66) Id. at 317.

(n67) See Accounting and Auditing Practices and Procedures: Hearings before Subcomm. on Reports, Accounting, and Management of the Senate Comm. on Governmental Affairs, 95th Cong., 1st Sess. (1977); Reform and Self-Regulation Efforts of the Accounting Profession: Hearings before Subcomm. on Oversight and Investigations of the House Comm. on Interstate and Foreign Com., 95th Cong., 2d Sess. (1978).

(n68) PREVITS & MERINO, supra note 30, at 318.

(n69) See id. ("This alleged lack of independence, [the report] contended, raises the prospect of a breakdown in confidence in the auditors' attest function.").

(n70) See, e.g., Robert Chatov, The Possible New Shape of Accounting in the United States, 4 J. ACCT. & PUB. POL'Y 161, 168-69 (1985). The SEC requires accounting firms to disclose non- audit services performed by auditors in excess of three percent of audit fees. PREVITS AND MERINO, supra note 30, at 318.

(n71) Accounting firms have long provided assistance to their clients with respect to problems clearly associated with the internal accounting functions. These consultations have gradually expanded to include a broad range of management activities such as marketing, production, and risk management that have but a tenuous relationship to accounting. Robert Chatov reports on a Wall Street Journal ad in which a C.P.A. firm classified its services "into two groups: the traditional ones like accounting and auditing, tax planning and management consulting; and the specialized ones that include financial institutions, health care, and emerging business." Chatov, supra note 70, at 163 (emphasis added; Chatov appears to be exercised over the classification of management consulting as a "traditional" service).

(n72) PREVITS & MERINO, supra note 30, at 318.

(n73) Id.


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