Brown & Co$.,$ CPAs, prepared tax returns for its client, King Corp. Based on the strength of King$$s tax returns, Safe Bank lent King $$500,000.$ Brown was unaware that Safe would receive a copy of the tax returns or that they would be used in obtaining a loan by King. King defaulted on the loan.

Safe commences an action for common law negligence against Brown. If Brown is able to prove that it prepared the returns in accordance with standards applicable to preparers, Brown will