Formal violations as a problem of the implementation by the departments of the FTS of Russia on the subjects of the Russian Federation of tax control

The article examines the problems of the activities of the Federal Tax Service Administrations in the constituent entities of the Russian Federation regarding the decision to reject complaints if the Inspectorate of the Federal Tax Service makes taxpayers liable for tax offenses. The analysis of judicial practice and material from the legal literature. It is proposed to resolve this issue at the legislative level, namely, to introduce a rule that can solve this problem.