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The existence of a dispute over fees generally does not relieve the CPA of this responsibility. IRS Circular also defers to requirements under state law. The laws and regulations concerning the return of client records and other documents for various states are set forth below.

The CPA may make and retain copies of such documents of the client when such documents form the basis for work done by him. Section c of the same rule appears to build in the requirement of payment by the client before any work product is released, as it defers to the terms of the engagement between the CPA and client. In Georgia, section A licensee[CPA] shall furnish to his or her client or former client, upon request made within a reasonable time:.

The Statement of Policy explains:. During the course of a professional engagement, a [CPA] may possess certain records of a client, or may have developed certain records without which the Client Records would be incomplete. Retention of Client Records after the client has made a request for them is a violation of Rule The [CPA] does not have a lien on these records, and they must be returned regardless of the fact that the fee of the [CPA] may remain unpaid.