纳税人诉讼是指以纳税人身份对政府的违法公共支出行为等向法院提起的诉讼。人民主权、保障人权、税收价格论为纳税人诉讼提供了理论基础,我国宪法赋予公民监督权的规定则是其法律依据。法治发达国家普遍建立了纳税人诉讼,并开展了丰富的诉讼实践。我国建立纳税人诉讼是保护公民私有财产权、建设公共财政和法治政府、推进宪政国家建设的重要保障,具有现实迫切性和深远意义。应当在行政诉讼法的修改和税法通则的制定中,对纳税人诉讼的受案范围、原告资格、举证责任等作出特别规定。 Taxpayer litigation refers to the action as a taxpayer on the government’s illegal public spending and other proceedings brought to the court. The people’s sovereignty, the protection of human rights, the tax price theory provide the theoretical basis for the taxpayer litigation, and the stipulation that our country’s constitution gives the citizen the right of supervision is its legal basis. Taxpayer lawsuits have been widely established in the developed countries with rule of law and rich litigation practice has been carried out. The establishment of taxpayer litigation in our country is an important guarantee for protecting citizens’ private property rights, building public finance and government under the rule of law, and promoting the building of a constitutional state. It is of great urgency and far-reaching significance. In the revision of the Administrative Procedure Law and in the formulation of the General Rules for Tax Law, special provisions shall be made on the scope of the cases accepted by the taxpayer, the qualifications of the plaintiff, and the burden of proof.