Choice "D" is correct. Reckless departure from standards of due care constitutes gross negligence, which is also called constructive fraud. A CPA who commits constructive fraud is liable to all plaintiffs, not just those with whom the CPA dealt or of whom the CPA knew.
Choice "a" is incorrect. Negligence connotes less of a departure from due care than does recklessness connote. If a CPA is merely negligent, liability is limited to clients and persons whom the CPA knew would be relying on the CPA's work.
Choice "c" is incorrect. Strict liability imposes liability without fault. CPAs generally are not strictly liable for departures from the standard of due care. Moreover, a fault standard (recklessness) is involved here.
Choice "b" is incorrect. Criminal acts give rise to criminal liability. Only the government can impose liability for criminal acts. Private parties must rely on a tort theory to hold a CPA liable.
