Legal analysis: Taxpayers and other taxpayers who are dissatisfied with the tax collection actions made by the tax authorities should first apply for administrative reconsideration to the reconsideration organ, and then bring a lawsuit to the people's court if they are dissatisfied with the reconsideration decision. Where an applicant applies for administrative reconsideration in accordance with the provisions of the preceding paragraph, he must first pay or remit the tax, late payment fee or provide corresponding guarantee in accordance with the tax decision of the tax authorities before applying for administrative reconsideration according to law. If the applicant refuses to accept the specific tax administrative acts other than taxation made by the tax authorities, he may apply for administrative reconsideration or bring an administrative lawsuit directly to the people's court.

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.