The tax is one of the most important sources that finance public revenues in the budgets of countries and may even be the only source of these revenues in some countries, so we see increased legislative and jurisprudential interest by the law of tax law and jurisprudence by finding all the legal and procedural means to maintain this source The judicial dispute within the framework of the tax law is one of these means that the taxpayer and financial management alike can resort to whenever appropriate as it has the ability to issue decisions binding to all parties and at all stages of litigation.