In Schnabel v. Superior Court (1993) 5 Cal.4th 704, the husband in dissolution proceedings was a 30 percent shareholder in a close corporation that had only one other owner. The husband's shares were community property. The Supreme Court held that on "the specific facts" of that case, the corporation's tax returns were discoverable. Its payroll tax returns were also discoverable, but only insofar as the information contained therein pertained directly to the husband. Information in the payroll tax returns that identified persons other than the husband need not be produced "absent a specific showing of relevance or need." (Schnabel, supra, 5 Cal.4th at pp. 722-723.) The marital dissolution exception has not been expanded further.