CASE 
2. 
Accounting 
for 
Enron 
Enron 
Corporation 
has 
come 
to 
symbolize 
their 
retirement 
savings 
when 
the 
one-time 
the 
worst 
of 
recent 
corporate 
corruption 
scan-seventh-largest 
United 
States 
corporation 
dals. 
Billions 
of 
dollars 
were 
lost 
by 
investors, 
went 
bankrupt, 
the 
largest 
bankruptcy 
in 
and 
thousands 
of 
people 
lost 
their 
jobs 
and 
history 
at 
the 
time, 
as 
a 
result·of 
the 
fraud 


From 
Joseph 
R. 
Desjardins 
andJohnJ. 
McCall, 
Contemporary 
Issues 
in 
Business 
Ethics, 
5th 
ed. 
(Belmont, 
CA: 
Thompson 
Wadsworth, 
2005). 



410 
Ethical 
Issues 
in 
Finance 
and 
Accounting 


created 
byitshighest-ranking 
executives. 
But 
the 
story 
of 
Enron 
is 
also 
the 
story 
of 
a 
failed 
watchdog 
system 
designed 
to 
prevent 
such 
fraud. 
Auditors, 
attorneys, 
and 
government 
officials 
who 
had 
responsibilities 
to 
protect 
investors 
and 
ensure 
the 
integrity 
of 
financial 
markets 
systematically 
failed 
to 
live 
up 
to 
their 
responsibilities. 


Enron's 
collapsebegan 
in2001whensome 
independent 
stock 
analysts 
and 
journalists 
publicly 
raised 
questions 
about 
the 
value 
of 
Enron's 
stock. 
At 
that 
time, 
Enron's 
stock 
was 
trading 
at 
more 
than 
$80 
a 
share, 
and 
Enron's 
CEOJeffrey 
Skillingwaspubliclyclaiming 
that 
itought 
tobevaluedatwellover$100ashare. 
During 
the 
summer 
of2001, 
several 
Enron 
insiders, 
including 
Vice 
Chair 
Clifford 
Baxter, 
Treasurer 
Jeff 
McMahon, 
and 
Vice 
President 
Sherron 
Watkins, 
all 
expressed 
doubts 
internally 
about 
Enron's 
financial 
practices. 
During 
this 
same 
period, 
other 
Enron 
insiders, 
including 
CEO 
Skilling 
and 
Board 
Chair 
and 
former 
CEOKenneth 
Lay,Enron's 
corporate 
counsel, 
and 
several 
board, 
members 
were 
selling 
millions 
of 
shares 
of 
Enron 
stock. 


InOctober 
2001whenArthurAndersen 
au


ditors 
finally 
reversed 
their 
previous 
decisions 


and 
restated 
Enron's 
financial 
situations, 
the 


collapseofEnronbegan 
inearnest.ByDecem


ber, 
when 
its 
stock 
was 
worth 
just 
pennies 
a 


share, 
Enron 
declared 
bankruptcy 
and 
dis


missed 
over 
4,000 
employees. 


Enron's 
collapse 
was 
mirrored 
by 
the 
collapse 
of 
its 
auditing 
firm, 
Arthur 
Andersen. 
Onceoneofthe"BigFive" 
accounting 
firms, 
Arthur 
Andersen 
was 
driven 
out 
of 
business 
byitsroleintheEnron 
scandal.OnJanuary 
9, 
2002, 
the 
United 
States 
Justice 
Department 
announced 
thatithadbegunacriminalinvestigation 
into 
Arthur 
Andersen's 
activities 
related 
to 
Enron. 
At 
the 
time, 
Arthur 
Andersen 
was 
already 
on 
probation 
by 
the 
SEC 
for 
its 
questionable 
accounting 
practices 
in 
previous 
scandals 
at 
Sunbeam 
Corporation 
and 
Waste 
Management. 
The 
next 
day,Andersen 
admit


ted 
that 
it 
had 
shredded 
thousands 
of 
documents 
related 
to 
its 
Enron 
audits. 
Five 
days 
later, 
Andersen 
fired 
David 
Duncan, 
an 
Andersen 
partner 
and 
head 
auditor 
for 
Enron. 
Soon 
after, 
the 
Justice 
Department 
indicted 
Arthur 
Andersen 
on 
charges 
of 
obstruction 
of 
justice. 
Finally, 
on 
June 
15, 
2002, 
Arthur 
Andersen 
was 
found 
guilty 
in 
a 
criminal 
trial 
of 
obstructing 
justice 
by 
shredding 
evidence 
relating 
totheEnron 
scandal 
and,asaresult, 
the 
firm 
agreed 
to 
cease 
auditing 
public 
companies 
byAugust 
3l. 


Records 
show 
that 
as 
early 
as 
May 
1998, 
Andersen's 
auditorswereexpressinggraveconcerns 
about 
Enron's 
financial 
practices. 
On 
that 
date, 
in 
an 
e-mail 
to 
David 
Duncan, 
Benjamin 
Neuhausen, 
amember 
ofAndersen's 
Professional 
Standards 
Group, 
expressed 
his 
thoughts 
on 
the 
Special 
Purpose 
Entities 
(SPEs) 
that 
were 
at 
the 
heart 
of 
the 
Enron 
scandal. 
"Setting 
aside 
the 
accounting, 
[sic] 
idea 
of 
a 
venture 
entity 
managed 
by 
CFO 
is 
terrible 
from 
a 
business 
point 
of 
view. 
Conflictsofinterest 
galore.Whywouldanydirector 
in 
his 
or 
her 
right 
mind 
ever 
approve 
such 
a 
scheme?" 
Neuhausen 
then 
went 
on 
to 
highlight 
the 
many 
accounting 
problems 
with 
the 
SPEs 
being 
managed 
by 
Enron 
CFO 
Andrew 
Fastow. 
Duncan 
replied, 
"But 
first, 
on 
your 
point 
1 
(i.e. 
the 
whole 
thing 
is 
a 
bad 
idea), 
I 
really 
couldn't 
agree 
more." 
Nevertheless, 
the 
Andersen 
auditors 
continued 
to 
cooperate 
with 
Enron 
by 
attesting 
to 
the 
soundness 
of 
Enron's 
financial 
statements. 


In 
February 
2001, 
more 
than 
a 
dozen 
Andersen 
auditors 
once 
again 
met 
to 
discuss 
thefinancialstatusofEnron's 
SPEs.Evidence 
shows 
that 
Andersen's 
auditors 
had 
serious 
concerns 
about 
the 
validity 
of 
Enron's 
financial 
self-portrait. 
In 
light 
of 
these 
concerns, 
they 
considered 
dropping 
Enron 
as 
an 
audit 
client. 
Michael 
Jones, 
one 
of 
Andersen's 
Houston 
employees, 
summarized 
the 
meeting 
in 
an 
e-mail 
to 
David 
Duncan, 
who 
also 
partieipated.
Jones' 
notesreveal"significantdiscussion 



.asheld 
regarding 
the 
related 
party 
transacions 
with 
LJM" 
(one 
of 
Enron's 
Special 
Purpose 
Entities). 
Apparently, 
several 
Andersen 
auditorsthought 
thatLJMcostsshouldnotbe 
ept 
off 
of 
Enrorr's 
books. 
Jones 
goes 
on 
to 
say,"The 
discussion 
focused 
on 
Fastow's 
con.
ctsofinterest 
inhiscapacity 
asCFOand 
the 
:"JM 
manager, 
the 
amount 
of 
earnings 
that 
Fastow 
receives 
for 
his 
services 
and 
participationinLJM,
thedisclosures 
ofthetransaction 
in 
the 
financial 
footnotes, 
and 
Enrori's 
BOD's 
~oard 
ofDirectors] 
viewsregarding 
the 
transactions." 
Enron's 
activities 
were 
described 
as 
"intelligent 
gambling," 
and 
Andersen's 
audi


ors 
acknowledged 
"Enrori's 
reliance 
on 
its 
current 
creditratingtomaintain 
itself,"its"dependence" 
onasupporting 
audittomeetitsfinancial 
objectives, 
and 
"the 
fact 
that 
Enron 
often 
is 
creating 
industries 
and 
markets 
and 
transactions 
for 
which 
there 
are 
no 
specific 
rules 
[and 
therefore] 
which 
requires 
significant 
judgment." 
Enron 
was 
also 
described 
as 
"aggressive" 
inthewayitstructured 
itsfinancial 
statements. 


But 
the 
risks 
of 
Enron 
were 
not 
the 
only 
issues 
discussed 
at 
that 
meeting. 
Andersen's 
auditors 
realized 
that 
Andersen 
was 
also 
doing 
significant 
consulting 
business 
with 
Enron, 
businessthatcouldbejeopardized 
byanunfavorable 
audit. 
"Wediscussed 
whether 
there 


vould 
be 
a 
perceived 
independence 
issue 
solely 
considering 
our 
level 
of 
fees. 
We 
discussed 
that 
the 
concerns 
should 
not 
be 
on 
the 
magnitude 
of 
the 
fees 
but 
in 
the 
nature 
of 
the 
fees. 
We 
discussed 
that 
it 
would 
not 
be 
unforeseeable 
that 
fees 
could 
reach 
$100 
million 
per 
year. 
Such 
amounts 
did 
not 
troubletheparticipants 
aslongasthe-nature 
of 
me 
services 
was 
not 
an 
issue." 
In 
the 
end, 
Andersen 
decided 
that 
the 
risks 
were 
worth 
laking. 
"Ultimatelytheconclusion 
wasreached 
to 
retain 
Enron 
as 
a 
client 
citing 
that 
it 
appeared 
that 
we 
had 
the 
appropriate 
people 
and 
processes 
in 
place 
to 
serve 
Enron 
and 
manage 
our 
risks." 


Ethical 
Issues 
in 
Finance 
and 
Accounting 
411 


Lessthanayearlater,Enrori's 
third-quarter 
financial 
report 
would 
reflect 
Andersen's 
new 
and 
different 
judgment 
concerning 
the 
SPEs. 
On 
October 
16,Enron 
reported 
aquarterly 
loss 
of$618 
million 
and 
announced 
mat 
asaresult 
of 
Andersen's 
auditing 
decisions, 
they 
would 
takea$1.2billionreductioninshareholder 
equity.
Withinoneweek,theSECannounced 
that 
it 
had 
opened 
an 
investigation 
into 
Enron's 
accounting 
practices. 
By 
the 
end 
of 
October, 
Enron's 
stockwastrading 
atjust$10pershare, 
analmosta90%drop 
in18months. 


ItisfairtosaythatAndersen 
overestimated 
their 
ability 
to 
manage 
the 
risks 
of 
Enron. 
Several 
decisions 
made 
byAndersen's 
professional 
staff 
during 
October 
proved 
to 
be 
disastrous 
for 
the 
company. 
On 
October 
12, 
as 
Andersen 
prepared 
for 
the 
public 
release 
of 
the 
new 
financial 
statements, 
Andersen 
attorney 
Nancy 
Temple 
advised 
head 
auditor 
David 
Duncan 
to 
get 
"in 
compliance" 
with 
Andersen's 
document 
retention 
policy. 
Because 
Andersen's 
document 
retention 
policy 
included 
directions 
to 
destroy 
documents 
that 
were 
no 
longer 
needed, 
Duncan 
interpreted 
that 
advice 
to 
mean 
that 
he 
should 
have 
Enron-related 
documents 
destroyed. 
Duncan 
then 
instructed 
Andersen 
employees 
to 
shred 
Enron 
documents. 
Duncan 
has 
acknowledged 
that 
he 
and 
others 
at 
Andersen 
were 
aware 
of 
a 
possible 
SEC 
investigation 
at 
me 
time. 


Four 
days 
later, 
on 
October 
16, 
Duncan 
shared 
a 
draft 
of 
a 
press 
release 
on 
Enron 
with 
Temple. 
In 
her 
role 
as 
Andersen 
attorney, 
Temple 
advised 
changing 
the 
press 
release 
to 
delete 
some 
language 
that 
might 
suggestthatAndersen's 
auditwasnotincompliance 
with 
Generally 
Accepted 
Accounting 
Principles 
(GAAP), 
as 
well 
as 
certain 
references 
to 
discussions 
within 
Andersen's 
legal 
group 
concerning 
Enron. 
Temple 
concluded 
her 
e-mail 
by 
promising 
to 
"consult 
further 
within 
the 
legal 
group 
as 
to 
whether 
we 
should 
do 
anything 
more 
to 
protect 
ourselves 



412 
Ethical 
Issues 
in 
Finance 
and 
Accounting 


from 
potential 
Section 
10issues" 
(Section 
10 
refers 
to 
SEC 
rules 
that 
require 
auditors 
to 
report 
illicit 
client 
activity). 
In 
early 
November, 
two 
weeks 
after 
they 
began 
shredding 
documents, 
Andersen 
received 
a 
federal 
subpoena 
for 
documents 
related 
to 
Enron. 
Only 
at 
this 
point 
did 
Temple 
advise 
Andersen 
to 
write 
a 
memo 
advising 
auditors 
at 
Andersen 
to 
"keep 
everything, 
do 
not 
destroy 
anything." 
By 
the 
end 
of 
November, 
the 
SEC 
investigationwasofficiallyexpanded 
toincludeArthur 
Andersen. 


At 
one 
time, 
Sherron 
Watkins 
was 
an 
Arthur 
Andersen 
auditor 
who 
worked 
on 
the 
Enron 
account. 
In 
1993, 
she 
left 
Andersen 
to 
join 
Enron, 
working 
for 
Andrew 
Fastow 
in 
Enron's 
finance, 
international, 
broadband, 
and 
finally, 
its 
corporate 
development 
division. 
Thus, 
for 
18years 
she 
participated 
in 
a 
wide 
range 
of 
Enron's 
business 
activities. 
In 
August 
2001, 
shortly 
after 
Jeffrey 
Skilling 
resigned 
as 
Enron's 
CEO, 
she 
wrote 
a 
memo 
to 
Kenneth 
Lay.Watkins 
became 
widely 
known 
as 
the 
Enron 
whistle-blower 
as 
a 
result 
ofthis 
memo, 
despite 
the 
fact 
that 
she 
had 
not 
expressed 
concerns 
earlier 
and 
she 
did 
not 
share 
her 
concerns 
with 
anyone 
outside 
of 
the 
company. 
In 
part, 
her 
memo 
to 
Lay 
reads 
as 
follows: 


Has 
Enron 
become 
a 
risky 
place 
to 
work? 
For 
those 
of 
us 
who 
didn't 
get 
rich 
over 
the 
last 
few 
years, 
can 
we 
afford 
to 
stay? 


Skilling's 
abrupt 
departure 
will 
raise 
suspicions 
of 
accounting 
improprieties 
and 
valuation 
issues. 
Enron 
has 
been 
very 
aggressive 
in 
its 
accounting-most 
notably 
the 
Raptor 
transactions 
and 
the 
Condor 
vehicle. 
We 
do 
have 
valuation 
issues 
with 
our 
international 
assets 
and 
possibly 
some 
of 
our 
EES 
MTM 
positions. 


The 
spotlight 
will 
be 
on 
us, 
the 
market 
just 
can't 
accept 
that 
Skilling 
is 
leaving 
his 
dream 
job. 
I 
think 
that 
the 
valuation 
issues 
can 
be 
fixed 
andreported 
withothergoodwillwrite-downsto 
occur 
in 
2002. 
How 
do 
we 
fix 
the 
Raptor 
and 
Condor 
deals? 
They 
unwind 
in 
2002 
and 
2003, 
we 
will 
have 
to 
pony 
up 
Enron 
stock 
and 
that 
won't 
go 
unnoticed 
.... 


It 
sure 
looks 
to 
the 
layman 
on 
the 
street 
that 
we 
are 
hiding 
losses 
in 
a 
related 
company 
and 
will 
compensate 
that 
company 
with 
Enron 
stock 
inthefuture. 
Iamincredibly 
nervous 
thatwewill 
implode 
inawaveofaccounting 
scandals.My8 
yearsofEnron 
workhistorywillbeworthnothing 
on 
my 
resume, 
the 
business 
world 
will 
consider 
thepastsuccessesasnothing 
butanelaborate 
accounting 
hoax.Skillingisresigning 
nowfor"personal 
reasons" 
but 
I 
would 
think 
he 
wasn't 
having 
fun, 
looked 
down 
the 
road 
and 
knew 
this 
stuff 
was 
unfixable 
and 
would 
rather 
abandon 
shipnowthan 
resign 
inshame 
in2years.... 


Is 
there 
a 
way 
our 
accounting 
gurus 
can 
unwind 
these 
deals 
now? 
I 
have 
thought 
and 
thought 
aboutawaytodothis,butIkeepbumping 
into 
one 
big 
problem-we 
booked 
the 
Condor 
and 
Raptor 
deals 
in 
1999 
and 
2000, 
we 
enjoyed 
wonderfully 
high 
stock 
price, 
many 
executives 
sold 
stock, 
we 
then 
try 
and 
reverse 
or 
fIx 
the 
deals 
in 
2001, 
and 
it's 
a 
bit 
like 
robbing 
the 
bank 
in 
one 
year 
and 
trying 
to 
pay 
it 
back 
two 
yearslater.Nicetry,butinvestorswerehurt, 
they 
bought 
at 
$70 
and 
$80 
a 
share 
looking 
for 
$120 
a 
share 
and 
now 
they're 
at 
$38 
or 
worse. 
We 
are 
under 
too 
much 
scrutiny 
and 
there 
are 
probably 
one 
or 
two 
disgruntled 
"redeployed" 
employees 
who 
know 
enough 
about 
the 
"funny" 
accounting 
to 
get 
us 
in 
trouble. 
What 
do 
we 
do? 
I 
know 
this 
question 
cannot 
be 
addressed 
in 
the 
all-employee 
meeting, 
but 
can 
you 
give 
some 
assurances 
that 
you 
and 
Causey 
will 
sit 
down 
and 
take 
a 
good 
hard 
objective 
look 
at 
what 
is 
going 
to 
happen 
to 
Condor 
and 
Raptor 
in 
2002 
and 
2003? 
.. 


I 
realize 
that 
we 
have 
had 
a 
lot 
of 
smart 
people 
looking 
at 
this 
and 
a 
lot 
of 
accountants 
including 
AA 
& 
Co. 
have 
blessed 
the 
accounting 
treatment. 
None 
of 
that 
will 
protect 
Enron 
if 
these 
transactions 
are 
ever 
disclosed 
in 
the 
bright 
light 
of 
day. 
(Please 
review 
the 
late 
90s 
problems 
ofWasteManagement 
whereAApaid$130million 
plus 
in 
litigation 
re 
questionable 
accounting 
practices.) 
... 


I 
firmly 
believe 
that 
executive 
management 
of 
the 
company 
must 
have 
a 
clear 
and 
precise 
knowledge 
of 
these 
transactions 
and 
they 
must 
have 
the 
transactions 
reviewed 
by 
objective 
experts 
in 
the 
fields 
of 
securities 
law 
and 
accounting.
IbelieveKenLaydeserves 
theright 
tojudge 
for 
himself 
what 
he 
believes 
the 
probabilities 
of 
discovery 
to 
be 
and 
the 
estimated 
damages 
to 
the 
company 
from 
those 
discoveries 
and 
decide 
one 
of 
two 
courses 
of 
action: 



l. 
Theprobabilityofdiscoveryislowenough 
and 
the 
estimated 
damage 
too 
great;therefore 
wefind 
awayto 
quietlyand 
quickly 
reverse, 
unwind, 
write 
down 
these 
positions/
transactions. 
2. 
The 
probability 
of 
discovery 
is 
too 
great, 
the 
estimated 
damages 
to 
the 
company 
toogreat;therefore, 
wemustquantify,develop 
damage 
containment 
plans 
and 
disclose. 
Ifirmlybelievethat 
the 
probability 
ofdiscovery 
significantlyincreased 
withSkilling'sshocking 
departure. 
Too 
many 
people 
are 
looking 
for 
a 
smokinggun.... 
Thereisaveilofsecrecy 
around 
LJM 
and 
Raptor. 
Employees 
questionouraccounting 
propriety 
consistentlyandconstantly. 
This 
alone 
is 
cause 
for 
concern 
.... 
Ihaveheard 
onemanager-levelemployeefrom 
theprincipal 
investments 
group 
say,"Iknow 
it 
would 
be 
devastating 
to 
all 
of 
us, 
but 
I 
wish 
we 
would 
get 
caught. 
We're 
such 
a 
crooked 


"1

company.... 


Another 
group 
of 
Enron 
insiders 
who 
were 
in 
position 
and 
had 
a 
responsibility 
to 
protect 
investors 
from 
fraud 
was 
Enron's 
Board 
of 
Directors, 
and 
particularly 
the 
Board's 
audit 
committee. 
In 
theory 
and 
in 
law, 
the 
board's 
primary 
responsibility 
is 
to 
represent 
the 
interests 
of 
shareholders. 
In 
practice, 
the 
board 
seemed 
less 
than 
vigilant 
in 
fulfilling 
these 
responsibilities. 
Enron's 
board 
approved 
of 
Andrew 
Fastow's 
violation 
ofthe 
corporate 
conflicts 
of 
interest 
prohibition 
when 
he 
negotiated 
contracts 
between 
Enron 
and 
the 
SPEs 
in 
which 
he 
was 
heavily 
invested 
and 
from 
which 
he 
profited 
tremendously. 
As 
Benjamin 
Neuhausen, 
one 
of 
Andersen's 
Enron 
accountants, 
claimed, 
the 
"ideaofaventure 
entitymanaged 
byCFOis 
terrible 
from 
a 
business 
point 
of 
view. 
Conflicts 
of 
interest 
galore. 
Why 
would 
any 
director 
in 
his 
or 
her 
right 
mind 
ever 
approve 
such 
a 
scheme?" 


The 
final 
line 
of 
defense 
against 
corporate 
fraud 
should 
be 
government 
officials 
and 
regulators. 
Arthur 
Levitt, 
chairman 
of 
the 
SEC 
throughout 
the 
1990s, 
strongly 
criticized 
the 


EthicalIssuesinFinanceandAccounting 
413 


dual 
auditing 
and 
consulting 
activities 
of 
the 
big 
accounting 
firms 
as 
involving 
conflicts 
of 
interest. 
Congress 
ignored 
his 
advice, 
apparently 
convinced 
by 
the 
lobbying 
efforts 
of 
the 
accounting 
profession 
to 
allow 
audit 
firms 
to 
continue 
working 
as 
consultants 
to 
the 
firms 
they 
audited. 


The 
federal 
government 
was 
also 
actively 
dismantling 
a 
wide 
range 
of 
financial 
regulatory 
protections 
during 
the 
1990s. 
During 
the 
first 
Bush 
Administration, 
the 
federal 
government 
deregulated 
the 
energy 
industry, 
ostensibly 
to 
spur 
economic 
growth 
according 
to 
free 
market 
principles. 
One 
of 
the 
leading 
advocates 
for 
this 
deregulation 
was 
Wendy 
Gramm, 
who 
at 
the 
time 
was 
chairwoman 
of 
the 
U.S. 
Commodity 
Futures 
Trading 
Commission. 
Gramm's 
husband 
is 
Phil 
Gramm, 
then 
U.S. 
Senator 
from 
Texas 
and 
a 
member 
of 
the 
Senate 
banking, 
finance, 
and 
budget 
committees 
that 
supported 
this 
deregulation. 
Senator 
Gramm 
had 
received 
over 
$100,000 
in 
campaign 
contributions 
from 
Enron 
during 
his 
last 
two 
Senate 
campaigns. 
When 
Wendy 
Gramm 
left 
government 
in 
1992, 
she 
joined 
Enron's 
Board 
of 
Directors 
as 
a 
member 
of 
their 
audit 
committee. 


Questions 


1. 
WhatresponsibilitiesdidDavidDuncanowe 
to 
Arthur 
Andersen? 
To 
Enrori's 
management? 
To 
Enron's 
stockholders? 
To 
the 
accounting 
profession? 
2. 
Whataretheethicalresponsibilitiesofacorporate 
attorney,suchasNancyTemple,who 
worksfor 
an 
"aggressive"client 
wishingto 
push 
the 
envelope 
oflegality? 
3. 
Under 
whatconditions 
shouldanemployee 
suchasSherron 
Watkinsblowthewhistleto 
outside 
authorities? 
To 
whom 
did 
she 
owe 
loyalty? 
4. 
Towhomdoesmeboardofdirectorsowetheir 
primary 
responsibility?Canyou 
mink 
ofany 
laworregulationsthatwouldhelp 
ensure 
mat 
boards 
meet 
their 
primary 
responsibilities? 

414 
Ethical 
Issues 
in 
Finance 
and 
Accounting 


5. 
What 
responsibilities 
do 
government 
regula-NOTES 
tors 
owe 
to 
business? 
To 
the 
market? 
To 
the 
general 
public? 
1. 
From 
a 
report 
released 
by 
the 
U.S. 
House 
of 
6. 
Are 
accounting 
and 
law 
professions 
or.busi-
Representatives 
Energy 
Committee, 
February 


nesses? 
What 
is 
the 
difference? 


2002.