Gerry, a calendar year taxpayer subject to a 36% marginal tax rate, claimed a charitable contribution deduction in 2018 of $800,000 for a painting that the IRS later valued at $500,000. The applicable overvaluation penalty is:

a. $108,000.

b. $43,200.

c. $21,600.

d. $5,000 (maximum penalty).

e. None of the above.