Taxpayer D was recently issued a civil fraud penalty connected to a fraudulent trust for splitting business income over multiple entities. D may be liable for

A$.$

Up to $75\%$ of the original taxes owed in addition to the tax underpaid.

B$.$

Up to $90\%$ of the difference between the taxes owed and the taxes paid.

C$.$

$100\%$ of the taxes owed.

D$.$

$100\%$ of the tax underpaid in addition to the taxes owed.