Which of the following is not a preparer penalty?

a.	Tax preparers may be assessed a penalty for failing to give the taxpayer the preparers workpapers.
b.	Tax preparers may be assessed a penalty for failing to keep a copy of the prepared return.
c.	Tax preparers may be assessed a penalty for endorsing or cashing a refund check issued to a taxpayer.
d.	Tax preparers may be assessed a penalty for failing to sign a tax return.