The state law rule of liability of accountants for negligence to third parties that is most favorable to the accountant is:

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The Ultramares doctrine limits an accountant's liability for negligence to third parties to those with whom the accountant had privity or a relationship that was so close as to approach that of privity. This is more favorable to accountants than the Restatement (Second) of Torts standard, which allows for liability to foreseeable third parties. The strict liability standard would be even less favorable to accountants as it would impose liability without considering fault or negligence. The foreseeability standard is also less favorable to accountants as it would allow for liability to third parties that the accountant did not have a close relationship with, but whose harm was foreseeable.

The State Law Rule of Liability of Accountants for Negligence