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Sybil, a tax return preparer, charged a taxpayer $600 to prepare his income tax return that claimed a $5,000 refund based on an unreasonable position.

Sybil, a tax return preparer, charged a taxpayer $600 to prepare his income tax return that claimed a $5,000 refund based on an unreasonable position. To what penalty is she subject if she knew the position was unreasonable but it was determined NOT to be the result of her willful and reckless conduct?

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