The Revenue Agent Who Audited Mr

The revenue agent who audited Mr.Silver's 2014 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 2014.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.