Which of the following statements is not correct in respect to tax return preparer penalties?

a. ‘The penalty for an understatement due to the preparer’s negligent or intentional disregard of one or more rules or regulations is $250; for willful understatement of liability the penalty is $1,000.

b. If a preparer in good faith and with reasonable basis takes the position that a rule or regulation does not accurately reflect the Code, he or she is not subject to either penalty.

c. The IRS has the burden of proof that a preparer has negligently or intentionally disregarded a rule or regulation.

d. Many Code sections require the existence of specific facts and circumstances. In order to avoid a penalty, a preparer shall make appropriate inquiries of the taxpayer to determine that the requirements have been met incident to claiming a deduction.