After Loving v$.$ IRS, the IRS still wanted to ensure competency of paid tax preparers and therefore instituted a voluntary Annual Filing Season Program. $$Peter the Preparer$$ has

participated in the program in the years $2017$ and $2018.$

$$ Peter did not participate in the voluntary Annual Filing Season Program in the years

$2015,2016,$ and $2019.$

$$ His client Terry Taxpayer has used Peter the Preparer for tax years $2015$ through $2019.$

a$)$ What $$practice before the IRS rights$$ does participating in the voluntary Annual Filing Season Program give to Tax Preparers?

b$)$ Are there any limitations in practice before the IRS for someone who participates in the voluntary Annual Filing Season Program?

c$)$ If Terry Taxpayer$$s $2015$ tax return is selected for audit in $2018,$ can Peter the preparer represent Terry before the IRS in $2018$ for the $2015$ return that was prepared and filed in April, $2016?$ Explain