In Holland v. Arthur Andersen & Co., 127 Ill. App. 3d 854, 866, 469 N.E.2d 419, 82 Ill. Dec. 885 (1984), the defendant accounting firm argued that the imputation doctrine was applicable to the trustee in bankruptcy. Although misconduct on the part of the defendant may also have been done in a knowing fashion by the principal, there were no allegations in the complaint which established that the purported misconduct on the part of the principal's top management was committed on behalf of the principal. The principal's complaint alleged that the purported misrepresentation served to artificially prolong the principal's business-life past the point of insolvency and that various corporate executive personnel would have needed to take steps to at least minimize the damage already sustained had they known of the misrepresentations. Thus, the Holland case involved fraud clearly committed by the companies' top management and, as a result, the companies were not able to benefit. The Holland court held that the misconduct of the agent could not be imputed to the principal. 127 Ill. App. 3d at 866.