《税收征管法》第五十六条规定,“纳税人、扣缴义务人、纳税担保人同税务机关在纳税上发生争议时,必须先依照法律、行政法规的规定缴纳或解缴税款及滞纳金,然后可以在收到税务机关填发的缴款凭证之日起60日内向上一级税务机关申请复议”。该规定并未包括税务罚款在内。相反,该条第二款 Article 56 of the Tax Administration Law stipulates that “when taxpayers, withholding agents, tax guarantors and tax authorities dispute over tax payments, they must first pay or remit tax in accordance with the law and administrative regulations and Late fees, and then you can apply for reconsideration to the tax authorities at the next higher level within 60 days upon receipt of the payment voucher issued by the tax authorities. ” This rule does not include tax penalties. On the contrary, the second paragraph of the article