A CPA firm performs the annual audit of The Leahy Group, a private company. Leahy asks the firm to determine whether the company would qualify for certain municipal tax credits and prepare the application. The firm will receive 15% of any tax credits that Leahy obtains as a result of the requested credits; if the request is denied, no fees will be due. Leahy does not expect city officials to perform a substantive review of its client's application. Which statement best describes why this fee arrangement would be a prohibited contingent fee arrangement under the AICPA Code of Professional Conduct?

a. Performing services for no fee creates a conflict of interest between the firm and Leahy. b. Performing the tax study would be considered a management responsibility. c. The firm does not expect the city to perform a substantive review of Leahy's application. d. The services are tax-related but may be significant both to the firm and Leahy.