Hill, a member, is preparing a tax return for Johnson for $20$X$3.$ There is a position on the $20$X$3$ tax return that is at odds with a tax treatment consented to in an administrative proceeding conducted on Johnson's $20$X$1$ tax return.Is Johnson bound to follow the tax treatment of an item as consented to in an earlier administrative proceeding? Johnson is not bound by the previous consent only if he receives permission from the IRSCommissioner. Johnson is not bound by the previous consent. Johnson is not bound by the previous consent only if he receives permission from the IRS. Johnson is bound by the previous consent.