James, a CPA, owns his own firm that prepares roughly 400 tax returns each year. In his office ate two college interns (Kelly and Lily) who screen/interview clients and do various administrative tasks for roughly 6 months of the year, a full-time receptionist who answers the phones (Mike), James' wife who keeps the firm s books and prepares and signs the firm's tax return, and Doug, an accountant who is not a licensed CPA but prepares various IRS forms including draft returns for James' review 6 months out of the year Out of the 400 returns James' firm prepares each year, roughly 85 contain claimed Earned Income Tax Credits ("EITC"). During the most recent tax year, a 16 year-old with $4,000 in earned income and a 2 year-old daughter comes into James' firm and states that she lives with her parents Kelly and Lily first interview the taxpayer and writes down her age. stated income, child age, and living arrangements on some paper and hands it to Doug. The taxpayer verbally tells Doug that she wants to treat her daughter as a qualifying child for purposes of the EITC Doug prepares a draft return, and gives it to James for review The return is prepared such that James will sign it Doug spends 1 hour preparing the draft return and James spends 15 minutes reviewing it James' firm charges the taxpayer $1, 200 for the return. a. Who in James' firm is practicing before the IRS for purposes of Circular 230? Why or why not? b. Who in James firm will be considered a tax return preparer under the Internal Revenue Code? Why or why not? c. What must (or should) James' firm do before preparing a return for the 16 year-old? d. Describe what possible penalties (and how each would apply) James may face under the Internal Revenue Code with respect to the 16 year-old's return, and under what circumstance(s) could James avoid them