Gloria,a Calendar Year Taxpayer Subject to a 35% Marginal Tax

Gloria,a calendar year taxpayer subject to a 35% marginal tax rate,claimed a charitable contribution deduction of $800,000 for a sculpture that the IRS later valued at $100,000.The applicable overvaluation penalty is:

A) $245,000.
B) $98,000.
C) $49,000.
D) $10,000 (maximum penalty) .
E) $0.