26 U.S.C. § 7610
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- (a)The Secretary shall by regulations establish the rates and conditions under which payment may be made of—
- (b)No payment may be made under paragraph (2) of subsection (a) if—
- (1)the person with respect to whose liability the summons is issued has a proprietary interest in the books, papers, records or other data required to be produced, or
- (2)the person summoned is the person with respect to whose liability the summons is issued or an officer, employee, agent, accountant, or attorney of such person who, at the time the summons is served, is acting as such.
- (c)This section applies with respect to any summons authorized under section 6420(e)(2), 6421(g)(2), 6427(j)(2), or 7602.