Gross income.
(3) Gross income. For purposes of section 7623(b)(5) and 301.76231 through 301.76234, the term gross income has the same meaning as provided under section 61(a). The IRS will compute the individual taxpayer's gross income, for purposes of award determinations described in 301.76233(c)(6), when there has been a final determination of tax as defined in 301.76234(d)(2).