Opportunities for enterprises to express their opinions include: notification, hearing, administrative reconsideration and administrative litigation. Enterprises need to correctly analyze the inspection results of tax authorities, which can be analyzed in detail from the following aspects: 1. When inspecting law enforcement, the written statements and arguments of the parties concerned shall be filed. The parties have statements and defense materials, which shall be filed; If an oral statement is made, a written statement shall be made and signed or sealed by the parties concerned; If the party waives the right to make statements or defend himself, he shall also make a record of defense, and fill in the words "the party has no statements or defense opinions", which shall be signed or sealed by the party and filed. This can avoid losing in administrative litigation cases. Because the "Administrative Punishment Law" clearly stipulates: "Refuse to listen to the statements and defenses of the parties, and the administrative punishment decision cannot be established." 2, when filling in the tax documents, the legal provisions are inaccurate, incomplete and not specific, and some only refer to the normative documents issued by the province or city as the basis for law enforcement; Some have no specific symbol, name or are omitted at will; The format of some tax documents does not conform to the provisions of relevant laws and regulations, and so on. These problems may be the factors of losing the case. 3. The evidence supporting the conclusion of tax treatment is insufficient. As the main evidence, the tax inspection draft should be signed by the parties before it can become effective evidence. 4. Failing to inform the parties of legal remedies in accordance with legal procedures. Some tax inspectors failed to inform the parties of their right to defend oneself, hearing, reconsideration and litigation according to the prescribed procedures before the implementation of administrative punishment; Some also issued the Notice of Tax Administrative Punishment and the Decision of Tax Administrative Punishment; Others have issued a tax administrative decision before the expiration of the legal time limit for the parties to apply for a hearing. These administrative penalties that do not conform to legal procedures are invalid according to the provisions of the Administrative Punishment Law. 5 did not produce the record of law enforcement inspection documents. In the process of law enforcement inspection, many inspectors neglect to take notes after showing their law enforcement inspection certificates, so that if the inspected person files a lawsuit against it, the tax authorities may lose because the law enforcement procedure is illegal. Therefore, in order to prove that the tax inspectors produced the law enforcement certificates during the inspection, and that the process of obtaining evidence was legal and effective, it is necessary to make inspection records including the inspection time, place, documents produced and inspection methods, and store them in the inspection files after being signed by the parties concerned. 6. Problems in the delivery of tax documents. Some penalty decisions are not signed by the parties on the delivery receipt. Even if there are, most of them are corporate accountants, and some have no time to sign. According to the provisions of the Administrative Punishment Law, when administrative punishment is implemented, the parties concerned should be informed not only of the facts, evidence and punishment basis of violation of the law, but also of the time limit and manner of their statement, defense, hearing, reconsideration and prosecution. The delivery of documents must have a receipt, a registered letter receipt, a newspaper sample, etc. To prove that the parties concerned have received the relevant documents or that the relevant documents have been served on the parties concerned. If a party fails to entrust a social intermediary agency, it shall directly serve it on the legal representative of the enterprise or the responsible recipient. 7. Incorrectly delivered tax documents to enterprises are often expressed by a third person as "your company", and should be changed to a second person as "your company" for targeted expression; In some penalty decisions, the payment time of the fine is often limited to a certain place before a certain day of a certain month of a certain year, which is contrary to the provisions of the Administrative Punishment Law that the parties should pay the fine at the designated bank within/0/5 days from the date of receiving the penalty decision. 8. Check the missing items in the penalty decision. The penalty decision must specify the specific illegal facts, evidence, nature and specific punishment basis, which are indispensable. 9. According to the Criminal Law, if the amount of tax evasion by taxpayers is more than 6.5438+0 million yuan, and the amount of tax evasion accounts for more than 654.38+0% of the taxable amount, criminal responsibility shall be investigated. Inspectors are often worried that cases that have been investigated for criminal responsibility will not be transferred and will only be punished in the end. 10. Improper punishment The most common way to punish tax evasion is to punish it according to the quota, which is inconsistent with the fine of 50% to 5 times of the taxable amount stipulated in the new tax collection and management law.