Legal analysis: If a party refuses to accept the punishment decision of the tax authorities, he may first apply for administrative reconsideration; if he refuses to accept the administrative reconsideration, he may bring a lawsuit to the people's court according to law. If a party refuses to accept the punishment decision of the tax authorities, it may apply to the tax authorities at the next higher level for reconsideration or bring a lawsuit to the people's court according to law; If it fails to apply for reconsideration, bring a lawsuit to the people's court and perform the punishment within the time limit, the tax authorities that have made the punishment decision may apply to the people's court for compulsory execution.

Legal basis: Article 12 of the Administrative Reconsideration Law of People's Republic of China (PRC) refuses to accept the specific administrative acts of the departments of local people's governments at or above the county level. The applicant may choose to apply for administrative reconsideration to the people's government at the same level or the competent department at the next higher level. If they are dissatisfied with the specific administrative acts of the administrative organs or state security organs that implement vertical leadership, such as customs, finance, national tax and foreign exchange management, they shall apply to the competent department at the next higher level for administrative reconsideration.