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Tax authorities file bankruptcy applications.
Legal subjectivity:

Since the tax authorities, as creditors, can't really participate in the reconciliation and reorganization of enterprises, at this time, it is unrealistic and unfavorable for enterprises to let a limited creditor (tax bureau) fully enjoy the rights of general creditors. Even in civil law, there are restrictions on the rights of persons with limited capacity. However, there are no restrictions on the liquidation of tax claims, which is obviously contrary to the principle of fair liquidation of claims and debts and protection of the legitimate rights and interests of creditors and debtors mentioned in Article 1 of the Bankruptcy Law.