28 Lazar, a member, is preparing a tax return for Polanski for 20x9. Lazar has prepared tax returns for Polanski for twenty years and a number of those returns have been audited, most recently for the year 20X7. There is a position on the 20x9 tax return that is at odds with a tax treatment consented to in an administrative proceeding conducted on Johnson's 2017 tax return. Is Polanski bound to follow the tax treatment of an item as consented to in an earlier administrative proceeding Polanski is bound by the previous consent. Polanski is not bound by the previous consent. Polanski is not bound by the previous consent only if he receives permission from the IRS None of the above