specified taxpayer

(7) Access to case files (A) In general In any case in which a conference with the Internal Revenue Service Independent Office of Appeals has been scheduled upon request of a specified taxpayer, the Chief of Appeals shall ensure that such taxpayer is provided access to the nonprivileged portions of the case file on record regarding the disputed issues (other than documents provided by the taxpayer to the Internal Revenue Service) not later than 10 days before the date of such conference. (B) Taxpayer election to expedite conference If the taxpayer so elects, subparagraph (A) shall be applied by substituting “the date of such conference” for “10 days before the date of such conference”. (C) Specified taxpayer For purposes of this paragraph— (i) In general The term “specified taxpayer” means— (I) in the case of any taxpayer who is a natural person, a taxpayer whose adjusted gross income does not exceed $400,000 for the taxable year to which the dispute relates, and (II) in the case of any other taxpayer, a taxpayer whose gross receipts do not exceed $5 million for the taxable year to which the dispute relates. (ii) Aggregation rule Rules similar to the rules of section 448(c)(2) shall apply for purposes of clause (i)(II).


26 USC § 7803(e)(7)

Scoping language

For purposes of this paragraph
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