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Question: SEC Independence and Non-audit Services. Is independence impaired on these SEC filing audits according to SEC independence rules regarding non-audit services?

a. CPA Dakota Tidrick is a staff assistant II auditor on the Section Co. audit. Upon the audit completion date in January, Tidrick drafted the balance sheet, income statement, comprehensive income statement, statement of cash flows, and notes for review by the engagement partner before the auditors' report was finalized.

b. CPA Mel Carnes is a manager in the firm's consulting division. He spent 100 hours with the Section Co. audit client on an accounts payable information system study, which involved selecting the preferred software and supervising Section Co.'s employees in startup operations.

c. CPA Nicky Webber, working in the public accounting firm's asset valuation consulting division located in Chicago, prepared for Section Co. an appraisal of the fair value of assets purchased in Section's merger with the Group Co. These valuations were then audited by the engagement team located in Dallas in connection with the purchase accounting for the merger.

d. CPA Fran Young is the engagement partner on the Section Co. audit and is also an actuarial consultant in the firm's consulting division. Young personally audited the client's postemployment benefits calculations, which had been prepared by Section's actuaries.

e. Section Co. appointed its own employee, certified internal auditor (CIA) Pat Mumta, to be director of internal auditing with complete responsibility for planning, management, and review of all internal audit work. Mumta engaged Section Co.'s independent public accounting firm to supply staff to perform all operational audit studies of efficiency and effectiveness in Section's domestic subsidiary companies. The public accounting firm used half of these same staff professionals to work on the audit of Section's financial statement audit.

f. CPA Dale Churyk is the partner in charge of the Dallas office where the Section Co. audit is managed (by engagement partner Jack). Churyk has no direct role on the audit engagement team. However, Section relies on Churyk to prepare the confidential papers for the board of directors' stock options and sign the release forms for option grants.

g. CPA Robin Mantzke works in the executive search department of the public accounting firm's consulting division, located in New York City. In connection with Section Co.'s hiring of its new vice president for marketing, Mantzke checked the references on the lead candidate Smith and performed a thorough background investigation that led to the firm's advice that Smith was the best person for the appointment. Section Co. board members investigated other candidates and hired Smith in Dallas without further interaction with Mantzke.

h. Section Co. completed a private placement of long-term bonds during the year under audit. The bonds were distributed to 40 qualified-exempt investors through the brokerage firm of Amalgamated Exchange Inc., which is 50 percent owned by the public accounting firm and 50 percent owned by Lynch Merrill Investment Corporation.

i. The public accounting firm's tax consulting division prepared Section Co.'s export import tax reports, which involved numerous interpretations of complicated export import tax law provisions.

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