Which of the following statements is true of accountants' liability?

A) The plaintiff only has to prove breach of duty in malpractice actions against accountants that are based on negligence.
B) All states follow the same guidelines to determine to whom an accountant can be held liable.
C) The Ultramares Doctrine allows third parties to sue accountants.
D) The smallest minority of states holds the accountant liable to any reasonably foreseeable user of the statement the accountant prepares.

D