This paper examines the state of tax notices in statutory interpretation.
While the legal system obliges administrative offi cials to follow tax notices, the notices are not a source of law and taxpayers and courts are not required to follow them.
However, tax notices play an important role in terms of tax jurisprudence for both administrative and taxpayers.
Therefore, the tax authorities should develop tax notices as necessary, and taxpayers should understand the tax notices and submit their opinions.