Period for Appeal to Arbitration Court of Tax Authority Decision Delivered according to Results of Consideration of Tax Inspection Files: Questions of Theory and Practice
Article deals with the disputable question concerning legal nature of the period, provided by part 4 of article 198 of the Code of Arbitration Procedure of the Russian Federation and the moment of its beginning. The above problem is examined in the context of the appeal of the tax authority decision, carried out according to the results of consideration of tax inspection files. The author examines examples of the judicial practice, which testify the difference in application of part 4 of article 198 of the Code of Arbitration Procedure of the Russian Federation by arbitration courts. The controversy on the validity of the duration of the established three-month period, and the needs for its abolition, is represented.