The Revenue Agent Who Audited Mr Silver's 2015 Form 1040

The revenue agent who audited Mr Silver's 2015 Form 1040 concluded that Mr Silver deliberately disregarded the tax rules about charitable contributions. Consequently, the agent disallowed $19,320 of Mr Silver's contribution deduction. Mr Silver also miscalculated his AMT in spite of his good faith effort to make the difficult calculation. Because of these two errors, the agent assessed a tax deficiency for 2015. Which of the following statements is false? 

A) The agent has the authority to impose a negligence penalty in addition to the deficiency.
B) The agent could impose a negligence penalty on the entire deficiency.
C) The agent could impose a negligence penalty on the portion of the deficiency attributable to the disallowed contribution deduction.
D) If the agent imposes a negligence penalty, Mr. Silver has the right to appeal the penalty.