(a) Every taxpayer is entitled to be reimbursed for any reasonable fees and expenses related to a hearing before the board if all of the following conditions are met:

1. (1) The taxpayer files a claim for the fee and expenses with the board within one year of the date the decision of the board becomes final.
2. (2) The board, in its sole discretion, finds that the action taken by the board staff was unreasonable.
3. (3) The board decides that the taxpayer be awarded a specific amount of fees and expenses related to the hearing, in an amount determined by the board in its sole discretion.

(c) The amount of reimbursed fees and expenses shall be limited to the following:

1. (1) Fees and expenses incurred after the date of the notice of determination, jeopardy determination, or denial of a claim for refund.
2. (2) If the board finds that the staff was unreasonable with respect to certain issues but reasonable with respect to other issues, the amount of reimbursed fees and expenses shall be limited to those which relate to the issues where the staff was unreasonable.