Obligaţia motivării în procedura de control fiscal – a organelor fiscale, a contribuabilului, a judecătorului sau a nimănui?
The obligation to motivate in the tax audit procedure – of the tax authority, the taxpayer, the judge or of no one?

Summary/Abstract: The reasoning in the tax control procedures, followed by the tax appeal against the issued administrative fiscal deeds, is not always assumed by the participants in these procedures. The lack of an effective reasoning, the gaps in the reasoning or the overly general reasonings, which to not target the real tax issue, can be found at all levels where the obligation to motivate intervenes: during the effective tax control, in the procedure of the settlement of the tax appeal or in the judicial procedure. This trend is growing and affects the clarification of the tax issue faced by the taxpayer.

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