(a) All information and records relative to any tax imposed by the Inheritance Tax Law acquired by the State Controller or by the inheritance or any assistant inheritance tax attorney is confidential in nature and, except as may be necessary for the enforcement of the law, cannot be divulged to any person other than a person liable for the tax or his duly authorized agent, or any local, state, or federal tax official.

(b) If the Controller has received the information to be divulged from the United States Internal Revenue Service, the person to whom it is divulged shall be advised of its source and that the confidentiality afforded thereto must be the same as if it were received directly from the Internal Revenue Service. Such information may be divulged only (1) to representatives of the Internal Revenue Service; (2) to the State Board of Equalization and the Franchise Tax Board; and (3) in judicial proceedings for enforcement of the California Inheritance and Gift Tax Laws.

Note: Reference: Section 14813, Revenue and Taxation Code.