Kate is a self-taught tax preparer. She advertises tax preparation for low fees and does other people's returns as a business to make extra income. She makes no claims in her advertising or to clients that she has any particular type of education or expertise with regard to tax preparation. One of her clients is audited and found to have filed a fraudulent return. The client is not only fined heavily, but is also sentenced to 30 days in jail. The client wants Kate to be held accountable for her preparation of the return, because the client relied on Kate's expertise. Would this scenario likely give way to a criminal trial, a civil trial, or both.