Eligible taxpayer. A taxpayer is an eligible taxpayer for a taxable year for purposes of this paragraph (e) if the av- erage annual gross receipts of the tax- payer for the three previous taxable years do not exceed $10,000,000 (the $10,000,000 gross receipts test) and the taxpayer has met the $10,000 gross re- ceipts for all prior taxable years begin- ning after December 31, 1994. For pur- poses of this paragraph (e)(2), the prin- ciples of section 263A(b)(2)(B) and (C) and § 1.263A–3(b) apply in determining whether a taxpayer is an eligible tax- payer for a taxable year.
Eligible taxpayer. A taxpayer is an eligible taxpayer for a taxable year for purposes of this paragraph (e) if the av- erage annual gross receipts of the tax- payer for the three previous taxable years do not exceed $10,000,000 (the $10,000,000 gross receipts test) and the taxpayer has met the $10,000 gross re- ceipts for all prior taxable years begin- ning after December 31, 1994. For pur- poses of this paragraph (e)(2), the prin- ciples of section 263A(b)(2)(B) and (C) and § 1.263A–3(b) apply in determining whether a taxpayer is an eligible tax- payer for a taxable year. A taxpayer is an eligible taxpayer for a taxable year for purposes of this paragraph (e) if the taxpayer is a small business taxpayer, as defined in § 1.263A–1(j).
Eligible taxpayer. For purposes of this section, the term ‘‘eligi- ble taxpayer’’ means—
