in 2023 (for 2022 tax returns filed in 2023), Taxpayer X and Taxpayer Y each agree to pay their tax preparer, Randy, from the refund they receive from the IRS. Upon presenting their refund checks to Randy, Randy pays them the difference in cash. Randy then endorses both checks and deposits them into his account. Randy has a Power of Attorney for Taxpayer X, but no Power of Attorney for Taxpayer Y.

A. Randy is subject to a penalty of $110

B. Randy is subject to a penalty of $55

C. Randy is a subject to a penalty of $560

D. Randy is a subject to a penalty of $1,120