Tax Collection Act Article 50-2

Any person subject to the imposition of penalty under this Act or any other applicable tax act shall be punished by the tax authorities, and the relevant provisions governing the penalty procedures as provided for under other tax acts shall not apply. If the person so imposed with a penalty disagrees with such punishment, said person may take appropriate action in accordance with administrative remedy procedures and, prior to the conclusion of the administrative remedy procedures, is not subject to the compulsory execution stipulated in Article 39 hereof.