Abstract
The Tax Procedure Code lays down a tax authority's duty to issue a notice of tax arrears before its first recovery. However, the law does not contain any specific consequence in case the tax authority does not do so.
There is no consequence inferred by the judicial decisions as well. The paper deals with the problems of this situation.
The paper aims to set consequences in case the tax authority does not issue a notice of tax arrears before the commencement of tax execution.