MCL 600.5838 governs the issue of accrual in cases alleging accounting malpractice. Ohio Farmers Ins Co v Shamie (On Remand), 243 Mich.App. 232, 238; 622 N.W.2d 85 (2000). A claim accrues when a defendant discontinues professional accounting services with respect to matters out of which the claim for malpractice arises.
(b) An act, omission, decision, or conduct of the certified public accountant that constitutes fraud or an intentional misrepresentation. Under MCL 600.5805(8), a two-year statute of limitations applies to professional malpractice actions, including accounting malpractice actions. Levy v Martin, 463 Mich 478, 482; 620 NW2d 292 (2001); Ohio Farmers Ins Co v Shamie, 243 Mich App 232, 236; 622 NW2d 85 (2000). MCL 600.5838(1) provides as follows regarding the accrual of a professional malpractice claim:
Under MCL 600.5805(8), a two-year statute of limitations applies to professional malpractice actions, including accounting malpractice actions. Levy v Martin, 463 Mich. 478, 482; 620 N.W.2d 292 (2001); Ohio Farmers Ins Co v Shamie, 243 Mich.App. 232, 236; 622 N.W.2d 85 (2000).
A plaintiff has two years from the date of accrual of a claim to file a claim of malpractice. MCL 600.5805(5); Ohio Farmers Ins Co v. Shamie (On Remand), 243 Mich. App. 232, 236; 622 N.W.2d 85 (2000). Accrual in this case is governed by MCL 600.5838(1), which provides in pertinent part:
In other words, "the plaintiff's claim accrues '[o]nce all of the elements of an action . . . are present." Ohio Farmers Ins. Co. v. Shamie, 622 N.W.2d 85, 88 (Mich. Ct. App. 2000). Hood's Complaint alleges that Chase's required appraisal was completed prior to the closing date of March 10, 2003.