It is essential that Finigan retain both an attitude of independence in fact and in appearance. It is not possible to determine if Finigan is maintaining an attitude of independence in fact, given her involvement in the company, but it is certainly possible that she is. Finigan is not necessarily violating the Code of Professional Conduct. She does the audit, tax return, bookkeeping and management services work for the client, but that is not a violation if Gilligan is a private company.