F M C Corp. v. Liberty Mutual Insurance Co

In F M C Corp. v. Liberty Mutual Insurance Co., 236 Ill. App. 3d 355, 603 N.E.2d 716, 177 Ill. Dec. 646 (1992), the court held that documents that were not likely to be disclosed to a third party but were transmitted only between the company and its accountant-auditor were not subject to disclosure. The court further recognized that "our legislature has determined that the accountant-client relationship is one of substantial significance and by enactment of section 27 of the Illinois Public Accounting Act (Ill. Rev. Stat. 1987, ch. 111, par. 5533) encourages people to make use of professional accounting services and to be frank and candid with such professionals. Accordingly, it is critical to our analysis that we do not carve out a series of exemptions that would emasculate the straightforward language of section 27." F M C Corp., 236 Ill. App. 3d at 358-59.