Douglas and Jacqueline Coe and their company relied on a tax strategy recommended by their accountants and obtained a legal opinion from Proskauer Rose before claiming losses on their tax returns. After the Internal Revenue Service challenged the strategy, the Coes settled and sued the law firm. The Supreme Court of Georgia held that the Court of Appeals had applied the wrong standard in concluding that the Coes could not prove an essential part of their claims as a matter of law. The record presented factual questions concerning what the law firm knew, what advice it gave, and whether the Coes reasonably relied on that advice. The Supreme Court reversed and remanded with direction to reverse the trial court’s order and allow further proceedings.