A tax return preparer may be subject to specific penalties:

a$.$ For procedural matters but not for understating a tax liability based on a position that lacks substantial authority.

b$.$ For failing to furnish the taxpayer with a copy of the return but not for failing to furnish the tax preparer's identification number.

c$.$ For willfully understating taxes by making no effort to obtain pertinent information from a client.

d$.$ For failing to file taxes for the same clients in consecutive years.

e$.$ For understating a tax liability based on a position that lacks substantial authority but not for procedural matters.