Section 19545 Of Article 2. Disclosure Of Information From California Revenue And Taxation Code >> Division 2. >> Part 10.2. >> Chapter 7. >> Article 2.
19545
. A return or return information may be disclosed in a
judicial or administrative proceeding pertaining to tax
administration, if any of the following apply:
(a) The taxpayer is a party to the proceeding, or the proceeding
arose out of, or in connection with, determining the taxpayer's civil
or criminal liability, or the collection of the taxpayer's civil
liability with respect to any tax imposed under this part.
(b) The treatment of an item reflected on the return is directly
related to the resolution of an issue in the proceeding.
(c) The return or return information directly relates to a
transactional relationship between a person who is a party to the
proceeding and the taxpayer which directly affects the resolution of
an issue in the proceeding.