NEW criteria for the Inland Revenue Department to open a property dealing file would allow more potential taxpayers to be assessed for profits tax, the Secretary for Treasury, Donald Tsang Yam-kuen, said. The criteria would apply to anyone who had three or more - instead of four or more - property transactions within a six-year period from April 1, 1987, or a single sale of property held for less than two years with gross profit arising from the sale exceeding $200,000.