Albert is Victor's accountant. In June 2021 Albert prepares a tax return for Victor's business. Victor sells his business to Peter in July 2022. Albert had not had any contact with Victor since doing the tax return and did not know the business was for sale. Victor used the figures in Albert's tax return to convince Peter to buy the business. Albert had been careless when he prepared the return and this mistake meant Peter paid too much for the business.

Advise Peter of any action he may have against Albert.

Issue: Does Albert owe Peter a duty of care?

Rule: Esanda Finance test - Esanda Finance v PMH