A taxpayer’s account is eligible for the managed audit program only if the taxpayer meets all of the following criteria:
(a) The taxpayer’s business or activities involve few or no statutory exemptions.
(b) The taxpayer’s business or activities involve a single or a small number of clearly defined taxability or liability issues.
(c) The taxpayer is taxed pursuant to this part and agrees to participate in the managed audit program.
(d) The taxpayer has the resources to comply with the managed audit instructions provided by the board.