Ackerman v. Price Waterhouse

In Ackerman v. Price Waterhouse (84 N.Y.2d 535, (1994)) the Plaintiff claimed that the cause of action for accountant malpractice accrued when Internal Revenue Service assessed deficiencies for tax returns which the defendant had prepared. The Court of Appeals held, however, that the cause of action accrued when the client received the accountant's work product. It reasoned that all of the facts necessary to the cause of action existed at that date even if the client was unaware of the malpractice or that she had been injured.