A client engages a CPA to provide bookkeeping services and provides the CPA with a client-prepared general ledger. The CPA prepares certain schedules including a depreciation schedule and fixed assets ledger for the client. The engagement is temporarily delayed, and the CPA returns no records to the client, as the client has not paid the CPA for any of the bookkeeping services. Five months later, the client requests that the CPA return the general ledger, depreciation schedule and fixed assets ledger. May the CPA withhold all of these records until the CPA is paid for services performed.