Gross income.
(3) Gross income. For purposes of section 7623(b)(5) and 301.7623-1 through 301.7623-4, 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 301.7623-3(c)(6), when there has been a final determination of tax as defined in 301.7623-4(d)(2).