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Will, a CPA, was paid $3,200 for preparing Mallory's tax return. The IRS later determined that Will took an unreasonable position on the return and

Will, a CPA, was paid $3,200 for preparing Mallory's tax return. The IRS later determined that Will took an unreasonable position on the return and assessed additional tax and penalties of $3,100. Will did not willfully attempt to understate Mallory's tax liability. What amount of tax preparer penalty is he subject to? 

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